Republic of the Philippines

DEPARTMENT OF JUSTICE
National Prosecutorial Service
OFFICE OF THE CITY PROSECUTOR
Santiago City

ARIEL DULDULAO,
Complainant,

-versus- CIVIL CASE NO. _________

For: Violation of Batas
Pambansa 22
REYMALON DELFIN PERALTA,
Respondent.
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AFFIDAVIT COMPLAINT

I, ARIEL DULDULAO, is of legal age, married, Filipino citizen

and a resident of _________________________, after having duly
sworn to in accordance with law do hereby depose and say :

1. That I am formally charging respondent REYMALON DELFIN

PERALTA, of legal age, Filipino, married and residing at Barangay
Daramuangan, San Mateo Isabela for violation of Batas Pambansa
22, otherwise known as Bouncing Checks Law committed as follows:

a) That I am engaged in the business of supplying construction

materials registered under the business name________. In the
course of my business, I agreed to supply construction materials such
as __________ to the respondent who has an ongoing project at San
Mateo, Isabela;

b) Sometime on the month of February 2019, I personally

delivered construction materials to the respondent with the
agreement that as payment of these transactions, the latter shall
issue check in my favor. In that same period of time, a postdated
check[1] was issued by the respondent in payment of his obligation
contracted for total amount of Php 230,000.00;

c) But to my dismay, when I personally presented the said

check before the drawee bank, BDO Santiago City Branch, under

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Annex”A”

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check number 0000127601 dated 3 May 2019, the said check was
dishonored due to Account Closed;

d) The respondent failed to settle the amount of Two Hundred

Thirty Thousand (Php 200,000.00) despite of being notified by the
bank;

d) I exerted efforts in trying to collect the obligation of the

respondent but it fell on deaf ears constraining me to engage the
services of counsel to prepare a formal demand letter dated 23 May
2019[2] wherein I demanded the payment of Two Hundred Thirty
Thousand Pesos (Php 230,00.00) within five (5) days from receipt
thereof;

e) Defendant acknowledged receipt of the demand letter stated

in the immediately preceding paragraph on __________ and after the
lapse of five (5), defendant did not pay its lawful, due and
demandable obligation;

f) But despite receipt of the demand letter asking for payment,

the respondent unjustly and unlawfully refused to pay his already due
and demandable obligation, thus, I suffered undue business reverses
and constrained to file a suit for BP 22;

2) Thus, I am formally charging the respondent for committing

the crime of violation of BP22 by making or drawing and issuing
check to apply on account or for value, knowing at the time of issue
that he does not have sufficient funds in or credit with the drawee
bank for the payment of such check in full upon its presentment,
which check is subsequently dishonored by the drawee bank for
account closed or would have been dishonored for the same reason
had not the drawer, without any valid reason, ordered the bank to
stop payment;

IN WITNESS WHEREOF, I have hereunto set my hand this

_______ day of _________2019, at Santiago City,Isabela.

ARIEL DULDULAO
Complainant
Drivers Lic.no.___________

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Annex “B”

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 SUBSCRIBED AND SWORN before me this ______day of
___________ 2019, at Santiago City Philippines; Affiant exhibited to
me his identifying evidence as required by the Rules, who signed the
said instrument in my presence. I further certify that I have personally
examined the affiant and I am convinced that the same is his own
free and voluntary act and deed.

_______________________
Prosecutor

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