Attention : Assignment for legforms 3-BDE tomorrow

Giant Panda, Inc., is a duly registered foreign-owned corporation engaged in the

business of manufacturing, storing and exporting of motorcycle and parts and with
principal place of business at Special Economic Zone II, Brgy. Canlubang, Calamba,
Laguna. It wants to buy the land and the factory on which its business is currently
located and negotiated with the owner of said lot and factory, North Park Realty
Corporation, with office address located at BGC, Taguig, Metro Manila for a purchase or
a longterm lease.
One year after the execution of the above Contract, your client North Park Realty
violated the Contract and was not able to deliver and upon further investigation, Giant
Panda found out that your client North Park and its President made
misrepresentations to Giant Panda and pocketed the money the latter paid by
virtue of the Contract. Giant Panda filed the appropriate Affidavit-Complaint against
the President of North Park Realty with the Prosecutor's Office.

If you were the Investigating fiscal, prepare the:

1. Complete Information for filing with the Appropriate Court.

After the Information was filed with the appropriate trial court, Assuming you are the
lawyer of the Accused -President, prepare the following:
2. Motion to Quash
3. Motion for a Bill of Particulars
. 4. Application And Motion for Bail

ESTAFA BY MEANS OF ABUSE OF CONFIDENCE

REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
National Capital Judicial Region
Branch 153, City of Taguig

PEOPLE OF THE PHILIPPINES,

Plaintiff,

Criminal Case No. 100290

For: Estafa
 - Versus –

JUAN JUNG PARK,

Accused.

X ----------------------- x

INFORMATION

The undersigned Assistant City Prosecutor, upon sworn complaint originally filed
by the offended party, accuses JUAN JUNG PARK if the crime of ESTAFA by means of
abuse of confidence, committed as follows:
That on or about March 12, 2018, in the City of Taguig, Philippines, within the
jurisdiction of this court, the said accused, having executed a long term lease contract
and received from VICKY VILLAPANDA an amount of FIVE HUNDRED FIFTY
THOUSAND PESOS (P 550,000.00) for the payment of the long term lease of land and
factory, under express obligation of turning over the said land after payment as
indicated in the contract, the said accused did then and there, willfully, unlawfully, and
feloniously, misappropriate, misapply and convert the said amount to his own personal
use and benefit to the damage and prejudice of said VICKY VILLAPANDA in the sum of
FIVE HUNDRED FIFTY THOUSAND PESOS (P 550,000.00) Philippine currency.

Contrary to law.
City of Taguig, Philippines, April 10, 2018.

(Sgd.) Atty. Pedro Mandirigma

Assistant City Prosecutor

CERTIFICATION OF PRELIMINARY INVESTIGATION