Tuesday, December 23, 2014

Rap vs rude driver of Hyundai Tucson

Rap vs rude driver 
of Hyundai Tucson

The Hyunday Tucson that is the subject of my complaint


As a new advocacy against arrogance on the road, I decided to write a formal Complaint-Affidavit to be filed against the owner of the Hyundai Tucson with plate no. VIN 494 and the driver of the same when the incident of rudeness complained of occurred.

As a brief of the incident, let me cite the post I wrote on Facebook walls to wit:

"RUDE DRIVER OF HYUNDAI TUCZON, VIN-494
"I was driving at 11:00 a.m. of 23 December 2014 along Quirino Avenue in Manila and I had just descended from Nagahan Bridge when I encountered this brown Hyundai Tuczon, plate no. VIN-494.
"I stepped on on the gas and I overtook this Hyundai Tuczon on my right.
"And while comfortably gaining speed I was kept at bay by the cars ahead of me that I cannot push ahead. At this moment, I noticed this Hyundai Tuczon dangerously closing in on the right side of my car as if the driver wanted to pin me to the road island. I slowed down a bit and the driver also slowed down, showing to me that the driver was mad because I overtook the Hyundai car. Because the traffic began to slow, I could not gain speed if only to overtake the Hyundai car again. However, the driver of the Hyundai car intentionally tried to prevent me from getting ahead of me by pinning me at bay.
"Sensing that to be an irresponsible act already, I asked my passenger Edsil Gadil to take a photo of the Hyundai and he did. I sought my staffer Helen Alquiza to get the name of the owner of the same SUV and she got it to be LILIA PATANI.
"Ms. Lilia Patani, I did not know who drove your SUV at that moment. But wait for the subpoena from the LTO for my complaint against the driver for rudeness and recklessness in driving."

The Complaint-Affidavit is below and those interested may read the same:



Republic of the Philippines
Department of Transportation and Communications
Land Transportation Office
East Avenue, Quezon City






ATTY. BERTENI CATALUÑA CAUSING,
                                                            Complainant,



            - versus -                                                       CASE NO. ______________




LILIA PATANI as owner of Hyundai Tucson
with plate no. VIN-494 and JOHN/JANE DOE
as the driver of the vehicle at the time of
occurrence of incident complained of,
                                                            Respondent.
x-------------------------------------------------------x
Republic of the Philippines          )
City of Manila                                  )SC





Complaint Affidavit





            I, ATTY. BERTENI CATALUÑA CAUSING, of legal age, single, whose office address is Unit 1, No. 2368 Leon Guinto St. corner JB Roxas St., Malate, Manila, after having been sworn to in accordance with law, do hereby depose and state:


1.     I am executing this Complaint-Affidavit to file a complaint for suspension of registration of the motor vehicle identified as brown Hyundai Tucson with license plate No. VIN 494 and suspension of driver’s license of the driver of the same vehicle at the time the incident narrated below occurred;


2.     I managed to get the name of the owner of the same Hyundai Tucson as LILIA PATANI whose address is listed as Block 6, Lot 1, Phase 3-E 1, Kaunlaran, Caloocan City;


3.     I am therefore filing this complaint for the suspension of registration of the same Hyundai Tucson;


4.     I am also filing formally the complaint for the suspension of the driver’s license of John/Jane Doe, the person who was actually driving the same vehicle at the time of the occurrence of the incident complained of as narrated below;


5.     I am a holder of Driver’s License No. NO2-94-241544, the present license is to expire on 2015-12-10 or 10 December 2015, a copy of which is attached hereto as ANNEX “A”;


6.     I am also a registered owner of Nissan Sentra, License Plate No. AAA-9455, a copy of the Certificate of Registration is attached hereto as ANNEX “B” and a copy of the latest Official Receipt No. is attached hereto as ANNEX “C”;


7.     About 11:00 a.m. of 23 December 2014, while driving to my office along Quirino Avenue, Manila, I encountered a Hyundai Tucson SUV, with license plate no. VIN-494, a copy of the photograph of the same vehicle is attached hereto as ANNEX “D”;


8.     While waiting for the green signal at the foot of Nagtahan bridge and facing the intersection of Quirino Avenue-Guazon St.-Jesus St., I was positioned at first in row of vehicles on the second lane from the left of the center-island of the foot of Nagtahan Bridge;


9.     While waiting for the traffic light signal to turn greed, I noticed a brown Hyundai Tucson at the right of my car;


10. The same Hyundai Tucson was also in the first of the row of vehicles in the third lane from the center of the bridge;


11. In other words, my car was abreast with the Hyundai Tucson;


12. When the green light for the go ahead toward Quirino Avenue and the green light for the left turn to Jesus St. turned on, I immediately stepped on my gas pedal and move ahead;


13. But because of the fact that those big trucks going to the left to Jesus St. were causing interference, I consumed a few seconds waiting for a clear path for me to move ahead straight to Quirino vehicles;


14.  As soon as I got a clear way, I accelerated straight forward aiming for the first lane from the center-island of Quirino Avenue and I succeeded, overtaking the Hyundai SUV in the process;


15.  After moving past a distance of 50 meters from the foot of the bridge, I slowed down a bit because there was another car who positioned ahead of me;


16. At this juncture, the Hyundai Tucson inched in so close to my car that our side mirrors nearly hit each other;


17.  The encounter was very, very dangerously close that I was forced to move my wheels to the left of my car if only to avoid the left side of the Hyundai SUV hitting the right side of my car;


18.  I stepped on my brakes to slow down a bit with the intention of letting the Hyundai SUV go ahead and in the process give me a clear path in the innermost lane;


19.  But the Hyundai SUV did not go ahead and instead it also slowed down to pin me to the center-island;


20.  To my mind, that was a manifestation that the SUV driver had the intention of pinning me never minding that his Hyundai vehicle would also get damaged on the left side;


21.  The act of pinning me lasted for about a minute before it accelerated ahead;


22.  Only at that instance that I got the plate SUV as the brown Hyundai Tucson with license plate number VIN 494;


23.  I thought that the driver of the Hyundai SUV got mad because I made the overtaking;


24.  Sensing that to be an irresponsible act already, I asked my passenger Edsil Gadil to take a photo of the Hyundai and he did;


25.  I sought my staffer Helen Alquiza who was seated at the back seat to get the name of the owner of the same SUV with license plate no. VIN 494 and she got it to be LILIA PATANI whose address is listed as Block 6, Lot 1, Phase 3-E 1, Kaunlaran, Caloocan City; and


26.  I am therefore executing this affidavit to file a complaint for acts of either reckless driving or intentional act of causing damage to another in order that the owner and the driver of the same Hyundai SUV are sanctioned with suspension of registration and drivers license.


IN WITNESS WHEREOF, I sign this Complaint-Affidavit on ____ December 2014 in Manila.




ATTY. BERTENI CATALUÑA CAUSING
Affiant

            SUBSCRIBED AND SWORN TO BEFORE ME on ____ December 2014 in Manila, affiant exhibited his Driver’s License No. NO2-94-241544 expiring on 10 December 2015.   I have examined the affiant and I am satisfied that he read and understood the foregoing affidavit and that nobody coerced or influenced him to execute the same.

Doc. No.:       ____;
Page No.:      ____;
Book No.:     ____;
Series of 2014.


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