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Department of Justice
NATIONAL PROSECUTION SERVICE
CITY PROSECUTION SERVICE OF MANILA
City of Manila
Related to:
COMPLAINANT/S RESPONDENT/S
Rm. 111-B Mercantile Insurance Bldg., #667 Pinaod, San Ildefonso, Bulacan
Gen. Luna cor. Beaterio Sts., Intramuros
Manila
WITNESS/ES:
Address:
MANGAOIL LAW OFFICE
Unit 10A Country Space 1 Bldg.,
Sen. Gil Puyat Ave., Makati City
IMPORTANT:
Complainant shall be required to file his complaint in the form of an affidavit to which must be
appended affidavit of witnesses, annexes and other supporting documents. The statements of the
complainant and his witnesses, annexes and other supporting documents. The statements of the
complainant and his witnesses shall, as far as practicable, be sworn to before the Investigating
Prosecutor. If sworn to before any officer authorized to administer oaths, the Administering Officer shall
CERTIFY THAT HE HAS PERSONALLY EXAMINED THE AFFIANT AND THAT HE VOLUNTARILY
EXECUTED AND UNDERSTOOD HIS AFFIDAVIT.
NOTE: Number of copies of affidavit of complainant/s and witness/es and other documents equal to:
COMPLAINT- AFFIDAVIT
I, NOEL M. BUMANGLAG, Filipino, of legal age, with office address at Rm. 111- B
Mercantile Insurance Bldg., Gen. Luna cor. Beaterio Sts., Intramuros, Manila, after having
been duly sworn in accordance with law, do hereby depose and state that:
3) As mentioned above, CTLC is engaged in the business of trailer leasing and other
allied services, and among its clients is a establishment engaged in trucking business, known
as WINSTON CHARLES MARKETING" owned and managed by
MR. HONORATO C. SAMSON & MS. LUISA V. SAMSON;
4) Said business establishment has its known office address at #667 Pinaod, San
Ildefonso, Bulacan, as represented by its Owners/Proprietors MR. HONORATO C. SAMSON
& MS. LUISA V. SAMSON with the same residence address at the
aforementioned business address, who are authorized to accept summons and legal
processes in all legal proceedings & all notices affecting the aforementioned establishment at
its aforementioned business address;
6) Commencing from January 2007, Winston Charles Marketing has failed to pay their
accounts regularly to CTLC which in turn made them incurred a total obligation of ONE
HUNDRED NINETY SIX THOUSAND FOUR HUNDRED EIGHTEEN PESOS and EIGHTY
FOUR CENTAVOS (PHP196,418.84) as reflected in the herein attached Statement of Account
as of January 08, 2008, and marked as
Annex B.
7) From that date onwards, CTLC found it hard to collect for payments from WINSTON
CHARLES MARKETING in spite of several demand letters which were sent to and received
by them;
10) Proper notifications and demand were made and sent to Mr. Honorato
Samson & Ms. Luisa Samson, the latter being the signatory of the check, so that they or
she could replace them with CASH and/or settle said accountability with the reason of
the return thereof. Copy of the latest demand letter is hereto attached and marked as
Annex E hereof;
11) In spite of the successive demand letter sent by our in-house counsel, MS.
LUISA V. SAMSON and/or WINSTON CHARLES MARKETING, failed and refused,
and continue to fail and refuse to redeem in cash the face amount of the unfunded
returned check. Filing of this case was even suspended for almost several times already
just to give them the ample time and opportunity to settle their obligations in full, but the
same served futile;
12) I am executing this affidavit to attest to the truth of the foregoing facts and for
the purpose of charging MS. LUISA V. SAMSON as one of the Owner/Proprietor of their
business WINSTON CHARLES MARKETING for violation of the provisions of
BATAS PAMBANSA BLG. 22.
By
NOEL M. BUMANGLAG
Affiant
ASSISTANT PROSECUTOR
I hereby certify that I have personally examined the affiant and that I am fully
satisfied that she voluntarily executed and understood her sworn statement.
ASSISTANT PROSECUTOR
3
COMPLAINT-AFFIDAVIT/BP Blg. 22 4
(CTLC v. WINSTON CHARLES MARKETING et al.)
SECRETARY'S CERTIFICATE
"RESOLVED, AS IT IS
HEREBY RESOLVED, That the
Corporation through the Board of
Directors, direct and authorize, as it hereby
directs and authorizes its General
Manager, MR. NOEL M. BUMANGLAG, to
institute and/or file a Criminal Case for
Violation of BP # 22 (Bouncing Checks Law)
against AUDLEY TRUCKING and/or MS.
RUBY ALBA-PAULINO, before the
appropriate tribunal/judicial body having
jurisdiction over the aforementioned case;
NOTARY PUBLIC