Republic of the Philippines

DEPARTMENT OF JUSTICE
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
Quezon City

NPS DOCKET NO.___________

ABRANTES MERCILY BAHINTING ROMULO

BANG ASAN MILAGROSA BULA MARILOU
BENDAEN ROSITA CABAGON ROGER
BANAGA PIA CAMPIANO JEHAN
BUEN SALOME CANOY JODERICK
BUSA JERRELYN CAPTE GENESIS
BARTOLOME MARY JANE CARIDAD NIMFA
BASA MARILOU CINCO MARINA
BATIS PERILYN CONTILLO SUSANA
BECHAYDA SHERWIN CRUZ GERRY
BENIGAY FELIX WELMA CRUZ LEMUEL EDSEL
BIBIT WILDEMINO CUMAMAO JOCELYN
BIGNAYAN JAONA CUMAMAO RODEL
BINGUIT GILBERT CURIG MYLENE
BINGUIT LEILANI DANN MATTHEW DALINO
BUDIA MICHIE DANN MITZELLE
ABRANTES RALPH DELA CRUZ NORALYN
ACPA ANAJANE DENOSTA NEAN
ALONZO VENICE DIAMANTE LEONORA
ARCARDO VINCENT DIZON OSMUNDO C.
ARIZALA LUDIVINA DOMINGO JOSEPH
ASUNCION EMILY DUMA OLIVER
ASUNCION EMMANUEL ECHANES CARINA
AVETRIA RACHELE JUMAWAN MYLIN
BACONES MARK GAJUDO MARIVIC
BACONES ROSALINDA GALABAYO ALVIN
BAHINTING CONCEPTION GARCIA GILMORE
GIANAN ROMULO HONRADA REYNALDO
GUEVARRA MERLITA IBARDOLAZA RAY
HONRADA MARIE CHINE LACAR ANTONIO
FAIR NATY MONTECLARO SAMMY
GAGATAM RISTY C. MORATO LODIELYN
FAMULERAS EDWARD MORATO ROBERTO
FANRESES JOEL NAAG EDWIN
FELISARTA VICTORIA NERA ROBERTO
FELIX ANTONIO NONES JHURAY
FENEQUITO MELLY ROSE NUNGAY ALFREDO
FRANCISCO ELISA OLERMO GRACE
FRANCON TEPASE ONCIANO RYAN
FUENTES CARMELITA OSTING ROGEL
GAGATAM CHARLIE PAGADORA JAYPEE
LACAR SUSARIE PALBUSA VIRGINIA
LEPALAN ANGELITO PANTAS LANNY GRACE
LIAZ ESTELITA PELIGRINO EDWIN
LLANERA JULIUS PELIGRINO LOVELY JOY
LOMOCSO ANALEA PINEDA JERRY
LOPEZ LUNINGNING PICAR IMELDA
LUNA MELANIE PICAR OSCAR
MANAOAG ELIAS JR. PRAYCO DAISY
MANITA JEORGE QUEVEDO AMOR
MANLANGIT ELY QUEVEDO ADELAIDA
MANLANGIT DELIA BEATRICE
MANUEL CORAZON QUIJANO JESUS
MARCIAL JUN QUION MONALIZA
MATAS FELIX RABINO BONIFACIO SOL
MESA CLARK HENRY REVESENCIO EDNA
MESA ROSIE RABINO LERMA SOL
MORALES JEROME RAMOS YOLANDA
MIAS JAPHET RELOS ANALYN
MONDRAGON MA. RITA RIZALADO VENUS
MONTECLARO ROSELLE ROBLES RICHARD
VICKY ROBLES JERICHO
ROBLES JEREMIAH PALBUSA VIRGINIA
ROBLES JERDYN ABLASA LIELA
ROBLES MICHELLE SHEKINAH JOY LACAR
ROBOSA IRENE HANNAH GRACE LACAR
ROGANDO RECHIE MATIAS CARL LACAR
SAMONTEZA JEANY ANNE JONATHAN RARA
SANTIAGO MAEDENNE ROELLA WHITE
JAMNE MITZI SEVILLA
SANTIAGO MARY ANN RONNIE DELA CRUZ
SARMIENTO HAYDEE CATHY PANGAN
SERRANA DICKSON EDUARDO TORRES
SERRANO LILIBETH EDRIAN TORRES
SOCCORO LOWELA MARJORIES LASACA
SUGUITAN LEONARDO INJILOU SEPRIA
TANGKIHAY ARMAN MARIDEL ARBIOLNINA
TRINIDAD NOMER MARIE ATIS
VALILA JOCELYN KAREN ANN DACUAN
VILLAREAL MARY JANE JANG RUTH
SORAIDA GUZMAN TAN NANCY
VEGA REYNA VITO ROWENA
VEGA JOHN VIC WANG VIRGINIA
VELMONTE MONALIZA YBANEZ JOEY
HOGR MOHAMMED QADER YGUINTO LILYBETH
LEGASPI ARVIN ROSARIO FRUGOSO
CANDA LOWELL ROLIE BALDESCO
HARANI FELIPE JR PEDROSA FRANCISCO
JUDAN ILDEFONSO TIU DULCE AMOR
SEVILLA MYRTZ MELODY BARDELAS ESPERANZA
FERNANDO BARDELAS JAMOSMOS MA. NATIVIDAD
PRINCESA PAGADORA GLENDA BACAY DIZON
JOAS RIVAS CONCEPCION VETE
CALLO RONALD GILDA BAUTISTA
ERIKA DE PEDRO LOURDES GAERLAN
ANGELITA LOPIDO AIDA FURIO
IMARGA JERSON JUAN FERLIZA
JOSOL JO-ANN JUDAN IDELFONSO
JUDAN FELIPA MARCIAL, JUN T.
SERAT MA. LINDA SERAT ALBERTO
MALICAY ROGELYN CATUBAY, JEWELL
GALABAYO GLAIZAFE GERARDO ESTUDILLO
ABDUL, DANTE EDMON, RON
ALINDOGAN, ERLINDA DARREN PAGUNSAN
LYN GACURA INTANO DONNA
VIVIAN DE PEDRO FELICITAS LIBERA
IBARDALOZA ROSEVE REYNALDO DIAMANTE
MATHEW S. MENDOZA ELMA TADEO
CATALINA MARTINEZ GERMAN DEGUZMAN

Represented by:
LEONARDO SAGUITAN,
JOHN VIC VEGA,
JOANA BIGNAYAN AND
AMOR QUEVEDO
Complainants,
-Versus-
Sky Enterprises Corp., CEO
and President, MR. LIMUEL VALLA,
MS. MARIA THERESA SINGSON,
MARK RONALD ZULUETA,
Vice President Sky Enterprises Corp.,
and the employees thereof namely
XILCA SINGSON, EMMANUEL
SABRINE, AJEN SABRINE, KIM
CHUA, GENS-BOYMATIN-AO,
NEO CALUZA, GLEN SADULIO
AND PAUL MACALO.

Respondents.
X--------------------------------------------------------/

COMPLAINT-AFFIDAVIT

COMPLAINANTS, represented by Leonardo Saguitan, Amor

Quevedo, John Vic Vega and Joana Bignayan, all of legal age, and all
residents of Metro manila, c/o 26 C, Traballo Building, Justice Lourdes
Paredes San Diego Avenue, (formerly Main Ave.), Cubao, Quezon City,
after having sworn under oath in accordance with law, hereby accuses
respondents, with office address located at 2nd floor, Jet Squad Building,
Citi Plaza Complex, Tandang Sora, Quezon City, with the crime of
Syndicated Estafa under P.D. 1689 in relation to Article 315 of the
Revised Penal Code of the Philippines, committed as follows:

UNDISPUTED FACTS

That during the months of August to October 2019, complainants

met the officers and employees of Sky Enterprise Corporation in the
person of Mr. Limuel Valla, CEO and President, Ms. Maria Theresa
Singson, Mark Ronald Zulueta, Vice President of Sky Enterprises Corp.,
and the employees thereof namely Xilca Singson, Emmanuel Sabrine,
Ajen Sabrine, Kim Chua, Gens-Boy Matin-ao, Neo Caluza, Glen Sadulio
and Paul Macalo at their former office address at Unit 105 Westrea
residences, 77 West Avenue, Brgy. Paltok, Quezon City, and at their new
office address located at 2nd floor, Jet Squad Building, Citi Plaza
Complex, Tandang Sora, Quezon City, respectively.
That during those months above mentioned, complainants put up
several Millions of Pesos BALLOONING TO A WHOPPING
Php57,257,000.00 Million Pesos more or less to the respondents due to
the inflated income the complainants supposed to earn contrived by the
respondents purposely to deceive and defraud the complainants herein.

That under the respondents’ deceivingly and fraudulently instituted

scheme used to entice unsuspecting individual which enticement actually
deceived and defrauded the complainants was through a program BUY
WAIT AND EARN wherein the subscriber of respondents’ product will
earn great cash back sale reward within just forty (40) days depending on
the packages offered by the respondents.

That the packages mentioned in the preceding paragraph are

hereunder provided as follows:

Starter Package Php1, 000.00 – Php9, 999.00 amount will be

doubled within forty (40) straight days;
 Silver Package Php10, 000.00 – Php99, 999.00 amount will be
tripled within forty (40) straight days; and

Gold Package Php100, 000.00 and above the amount subscribed will
be quadrupled within forty (40) days of subscription.

That 10% daily immediately after date of subscription up to 40 days

thereon shall be given back to the subscriber until the subscription amount
shall be returned plus the inflated income depending on which package/s
is subscribed as mentioned above.

That the income of the amount put up by complainants as indicated

in the preceding paragraph computed based on the contrived scheme
thereof, complainants will receive the aggregate amount of
Php221,642,000.00 Million Pesos of which none of the amount,
composing of the initial capital and the supposed income, was ever
returned by the respondents to the complainants.

That due to the said deceptive and fraudulent scheme complainants

was innocently duped and unsuspectingly lured to avail of the deceptive
and fraudulent offers of the respondents thereby amassing Millions of
Pesos therefore.

Complainants bequeathed their trust with the respondents and spend

their money to avail with the respondents offer but the inflated income
which the complainants supposedly have to incur as signified by the
respondents have gone to naught. Without a doubt, an investment scam.

Had it not for the very enticing inflated income the respondents
offered to the complainants when none of it was actually intended to be
given to herein complainants, they would not have succumbed and
resultantly dole out their hard earned money and eventually being duped
and rip-off by the respondents overwhelmingly.

Complainants were made prey by the respondent through deceit,

fraud and sham propositions, “an investment scam”, without any
intentions of binding itself and therefore should be indicted for Syndicated
Estafa and such other offences the Honorable Investigating Prosecutor
may find sufficient according to the circumstances.

That the actions of the respondents in promoting and enticing a

scheme deceptively and fraudulently structured for the sole purpose of
deceiving and defrauding another thus causing boundless damage to its
prey fall squarely to the criminal offense herein mentioned. Consequently,
the respondents should be indicted for Syndicated Estafa.

That complainants made demands in several instances, personal and

through text messages, that the respondents will perform their end of the
bargain and provide what is due the complainants but to no avail.

That the elements of the crime of Estafa by means of deceit under

par. 2(a), Article 315 of the Revised Penal Code are:

a) That there must be a false pretense, fraudulent act or fraudulent

means;
b) That such false pretense, fraudulent act or fraudulent means must
be made or executed prior to or simultaneously with the
commission of the fraud;
c) That the offended party must have relied on the false pretense,
fraudulent act, or fraudulent means; that is, he was induced to part
with his money or property because of the false pretense,
fraudulent act or fraudulent means; and
d) That as a result thereof, the offended party suffered damage.

The elements of syndicated estafa are: (a) estafa or other forms of

swindling as defined in Article 315 and 316 of the Revised Penal Code is
committed; (b) the estafa or swindling is committed by a syndicate of five
or more persons; and (c) defraudation results in the misappropriation of
moneys contributed by stockholders, or members of rural banks,
cooperatives, “samahang nayon(s),” or farmers’ associations or of funds
solicited by corporations/associations from the general public

The Supreme Court has ruled that to be criminally liable under P.D.
1689, one need not necessarily threaten the economic stability of the
nation; it is enough that the acts complained of contravenes public interest.

All the above elements are present in the case at bar, thus warranting
the application of P.D. 1689 with the consequent increase in the penalty
of life imprisonment to death.

That attached are the copies of the receipts of pay-ins received by

complainants upon payment of the packages subscribed as Annex “A”.
the summary of the amount invested and the total amount of collectibles
as annex “B”.

Complainant-affiants executes and file this criminal complaint to

attest to the truth of the foregoing and to prosecute the aforementioned
respondents for the offenses mentioned above.

IN WITNESS WHEREOF, complainant-affiants hereunto affixed

their signature this ____day of November 2019, at Quezon City,
Philippines.

Complainant-affiants:

AMOR QUEVEDO JOHN VIC VEGA

LEONARDO SAGUITAN JOANA BIGNAYAN

SUBSCRIBED AND SWORN TO BEFORE ME this ____day of

November, 2019, at Quezon City, Philippines, exhibiting to me their
officially issued identification bearing their pictures and signatures.

The undersigned certifies that he/she personally examined the

affiants and that he/she is satisfied that they voluntarily executed and
understood their affidavit-complaint.