REPUBLIC OF THE PHILIPPINES)

CITY OF MANILA ) S.S.

COMPLAINT-AFFIDAVIT

I, JUAN DELA CRUZ, of legal age, Filipino, single, and a resident of No. 123 Sampaloc,

Manila, Philippines, after being sworn to in accordance with law, depose and state:

That I know the person of John Doe, who is a resident of No. 456 Santol Quezon City, Philippines;

That sometime in the morning of October 2017, at 789 Manga Street, Manila, Philippines, the said

John Doe issued in my favor a BPI Check No. 12345 in the amount of P110,000 as supposed

payment for the loan accommodation of P100,000, which I have extended to her;

That the said check is drawn against the account of the said John Doe at BPI with Account No.

1234-5678-90;

That at the time the said John Doe issued and delivered the said check to me, he made the assurance

and representation that the said check is a good check and would be covered by sufficient funds

when presented for payment;

However, when the above-mentioned check was deposited, the same was dishonored and returned

by the bank on the ground that the same was drawn against a “CLOSED ACCOUNT”. A true and

faithful machine reproduction of the said check is attached as Annex “A”;

As such, I immediately notified said John Doe of the dishonor and return of the said check and

demanded from him that he make good the said check within five (5) days from the receipt thereof.

A true and faithful machine reproduction of my demand letter to him is hereto attached as Annex

“B”;
When said John Doe failed to heed my demands, I endorsed the said check to my legal counsel

who immediately sent a formal letter through registered mail with return card on November 20,

2017, which was received by the said John Doe on November 28, 2017. As of date however, John

Doe has unjustifiably ignored all these demands to pay the said account and/or to redeem the said

returned check. A true and faithful machine reproduction of my demand letter to him is hereto

attached as Annex “C”;

I am therefore executing this Complaint-Affidavit in support of the charges for Violation of Batas

Pambansa Bilang 22 against the said John Doe, who may be served with subpoena and other

processes of this Honorable Office at his last known address at No. 456 Santol Quezon City,

Philippines.

IN WITNESS WHEREOF, I have hereunto set my hand this 6th day of January, 2018 at Manila,

Philippines.

JUAN DELA CRUZ

Affiant-Complainant

CERTIFICATION

SUBSCRIBED AND SWORN to before me this 6th day of January, 2018 at Manila,

Philippines. I hereby certify that I have personally examined the affiant and I am satisfied that she

has voluntarily executed and understood the contents of his Complaint-Affidavit.

PEDRO SANTOS
Office of the City Prosecutor