Republic of the Philippines)

City of Cebu ) S.S.

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COMPLAINT- AFFIDAVIT

That I, Kvyn R. Honoridez, of legal age, single, Filipino and

a resident of 183 Carreta, Cebu City, after having been duly
sworn to according to law hereby depose and say:

1. That I am the Credits and Loans Manager of East West

Bank, Archbishop Reyes Ave. Branch, Cebu City. I am
executing this affidavit in behalf of East West Bank,
being the complainant herein.

2. In behalf of the said Bank, I am filing a formal complaint

for Estafa thru Falsification of Public Document and /or
thru Forgery against respondent Katrina M. Regalado
[hereinafter Respondent], a resident of Kamagayan,
Cebu City .

3. On January 15, 2016, Respondent using the name of,

and misrepresenting herself to be Doa Karencitta
Lizarraga- Hermanos, submitted a loan application,
purportedly signed by the Spouses, by forging their
signatures with East West Bank, Archbishop Reyes Ave.
Branch, Cebu City amounting to PhP 5,000,000.00.

4. As security for the payment of the said loan,

Respondent submitted as collateral thereof a parcel of
land described in TCT No. T-49549 and executed a Real
Estate Mortgage over the said land in favor of East West
Bank.

5. On January 23, 2016, the loan application amounting to

Philippine Pesos: Five Million (PHP 5,000,000.00) was
approved by East West Bank and the proceeds thereof
were delivered to the Respondent, receipt of which is
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 evidenced by a managers check issued by the bank
and withdrawn by the Respondent. Photocopy of the
said check is hereto attached as Annex C hereof;
6. On February 6, 2016, South Bank found out that
respondent falsified and/or forged the above mentioned
documents. It also found out that Respondent
misrepresented herself to be Doa Karencitta Lizarraga-
Hermanos when in truth and in fact the former, as
found by the bank, is Katrina M. Regalado.
Respondents real identity was discovered by the bank
when one of its employees identified her as an
acquaintance as they live in the same barangay and is
personally known to her;

7. Respondents unlawful acts were discovered by the

bank when the latter tried to collect from the Spouses
Hermanos who refused to pay on the ground that they
did not apply for a loan, much less mortgage the land
covered by subject land title in favor of East West Bank;

8. The unlawful acts by Respondent caused damage and

prejudice to East West Bank in the amount of PhP
5,000,000.00, the amount released to respondent as
proceeds of the loan, including interest of twelve
percent (12%) per annum;

9. East West Bank spent PhP 30,000.00 for attorneys fees

for filing the complaint affidavit .

10. That I am executing this affidavit for and behalf of

the East West Bank, Archbishop Reyes Ave. Branch,
Cebu City, being the Credits and Loans Manager
thereof, to file a formal complaint of Estafa through
Falsification of Public Documents and/or through
Forgery against Katrina M. Regalado.

IN WITNESS WHEREOF, I have hereunto affixed my

signature for and in behalf of the complainant East West

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Bank, Archbishop Reyes Ave., Cebu City this 8 th day of
February 2017, at Cebu City.

Kvyn
R. Honoridez
Affiant

JURAT

SUBSCRIBED and SWORN to before me this 8th day of

February, 2017, at Cebu City. I hereby certify that I have
personally examined the above-named affiant and that I am
satisfied that the foregoing statements were given by him
voluntarily and of his own free will.

ATTY. ESMACJUN P. ESPADILLA

Notary Public within and for the territorial jurisdiction of
The RTC of Cebu City, San Fernando, and Carcar City
Notarial Commission No. 144
Until December 31, 2018
Roll of Attorneys No. 2223
MCLE Compliance Certificate V No. 1113, 1/3/2017
PTR No. 2223, 1/5/2017, Cebu City
IBP No. 2223, Lifetime, Cebu City
Suite 04, RC Towers
Talamban, Cebu City, 6000