REPUBLIC OF THE PHILIPPINES

Paniqui, Tarlac

)
) S.S.

COMPLAINT-AFFIDAVIT
I, LINA CASTILLO-ARANDA, of legal age, American citizen, formerly Filipino, widow, and a
resident of Artacho, Bautista, Pangasinan, states under oath that:
1. I am instituting this CRIMINAL COMPLAINT against the Spouses REYNANTE RAMOS &
MARYJANE RAMOS (Spouses Ramos), both of legal age, Filipinos, and residents of Brgy. Sta. Monica,
Tarlac, SWINDLING (ESTAFA) as defined and penalized under Article 315 (1) (b) of the Revised Penal
Code of the Philippines, as amended.
2.

The Spouses Ramos committed the act/s complained of as follows:

a)

Sometime in November 2011, the Spouses Ramos and I had an agreement to lend money to some
farmers in Moncada, Tarlac. The funds would come from me and the spouses would be the ones
to give the amount to the intended debtors. The debtors/farmers, in return, will mortgage their
agricultural land to me and I authorized the Spouses Ramos to cultivate the land while the debt
remains unpaid. I would take care of all the expenses in cultivating the land while the Spouses
Ramos would provide the labor. All produce from the land mortgaged to me, after deducting the
expenses, shall be divided between me and the Spouses Ramos in equal shares.

b) In accordance with our agreement, on November 2011, I sent through money remittance the
amount of TWO HUNDRED THOUSAND PESOS (Php200,000.00) to Mrs. Susana Macamus,
the mother of Maryjane Ramos. The amount was supposed to be paid/given to Mr. Esteban
Ramos of Sitio Tambo, Sta. Monica, Moncada, Tarlac, who mortgaged his agricultural land to
me. The Spouses Ramos received the entire amount of Php200,000.00 from Mrs. Macamus.
c)

To my surprise, only the amount of Php120,000.00 was given to Mr. Esteban Ramos, as
evidenced by a Promissory Note he executed on 4 December 2011 in Sta. Monica, Moncada,
Tarlac, a copy of which is hereto attached as Annex A to form an integral part hereof. The
amount of Php120,000.00 had been returned/paid to me by Mr. Esteban Ramos.

d) I confronted the Spouses Ramos about the remaining Php80,000.00 out of the Php200,000.00 that
I gave them. They told me that they already used the money for their personal use. I demanded
the return of the Php80,000.00 but they told me that they did not have any money, to my damage
and prejudice.
e)

On December 2011, I again sent through money remittance the amount of TWO HUNDRED
THOUSAND PESOS (Php200,000.00) to Mrs. Susana Macamus, who delivered the entire
amount to the Spouses Ramos. The money was supposed to be paid/given to Mr. Orlando
Ramos, also of Sitio Tambo, Sta. Monica, Moncada, Tarlac, who also mortgaged his agricultural
land to me.

f)

I discovered, however, that the entire amount of Php200,000.00 was not given/loaned to Mr.
Orlando Ramos. Instead, only the amount of FORTY SEVEN THOUSAND PESOS
(Php47,000.00) was given to Mr. Orlando Ramos. The Spouses Ramos used the remaining
Php153,000.00 for their personal gain, to my damage and prejudice. Attached hereto as Annex

B is the Sinumpaang Salaysay of Mr. Orlando P. Ramos to prove that he received the amount
of Php47,000.00 only from the Spouses Ramos.
g) Also attached to this Complaint-Affidavit as Annex C is the Sinumpaang Salaysay of Gil C.
Cabontocan to prove that I remitted the money to Mrs. Susana Macamus.
h) Finally, on November 2011, at my house in Artacho, Bautista, Pangasinan, I personally gave the
amount of FORTY SEVEN THOUSAND PESOS (Php47,000.00) to the Spouses Ramos, to be
used in the purchase of farming equipment needed for the cultivation of the farmlands in
Moncada, Tarlac which were mortgaged to me. I discovered, however, that the Spouses Ramos
did not use the money to buy any piece of equipment. Instead, they used the money for their own
personal use/consumption. I demanded from them the return of the said amount, but they refused
and/or failed to do so, to my damage and prejudice.
3. The above unlawful acts of the Spouses Ramos caused damage and prejudice to me in the amount
of Php280,000.00. The amount was supposed to be given to other persons and used for the purchase of
farming equipment but was appropriated by the Spouses Ramos for their own personal use and/or
consumption.
4. I filed a complaint before the Barangay Council of Sta. Monica, Moncada, Tarlac against the
Spouses Ramos for estafa and demanded the return of the Php280,000.00 given to them. However, no
amicable settlement was reached since the Spouses Ramos allegedy have no money or property to pay me.
Copies of the Barangay Blotter and Certification to File Action issued by the Office of the Lupon
Tagapamayapa in Brgy. Sta. Monica, Moncada, Tarlac, are hereto attached as Annexes D, E and F to
form integral parts hereof.
5. I am executing this Affidavit to attest to the truth of the foregoing statements and for the purpose
of prosecuting the Spouses REYNANTE RAMOS and MARYJANE RAMOS for the crime of SWINDLING
(ESTAFA).
IN WITNESS WHEREOF, I sign hereunder on this 11th day of March 2013 at Paniqui, Tarlac.
_______________________
LINA CASTILLO-ARANDA
Affiant/Complainant

SUBSCRIBED AND SWORN before me on this 11th day of March 2013 at Paniqui, Tarlac.
I hereby certify that I have personally examined the complainant and that I am convinced that the
foregoing is his true and voluntary act and deed.
MICHELLE SALGADO
Associate City Prosecutor