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COMPLAINT-AFFIDAVIT

I, Ma. Isabel Macalintal y Antillon, Filipino, of legal age, married, with address at 130 Halcon
Street Barangay San Isidro Labrador Quezon City, after being duly sworn in accordance with
law, do hereby depose and state that:

1. Respondent is Mr. Francisco Repol, Filipino, of legal age, with residence at 136-
A. Halcon St., La Loma, Quezon City, where he may be served with subpoena,
and other processes;

2. Sometime last October 2014, respondent convinced me to invest the amount of


Php680,000.00 for the production of a film called “Eh Kasi Bata”, on the promise
that said film would be produced and released for commercial distribution, and
the profits therefrom would be divided between us. Based on such
representation, I gave him the amount in cash, and awaited news on the
completion of the film project. A copy of the receipt he signed as evidence of our
agreement is attached hereto as Annex A;

3. Despite repeated inquiries, he failed to give a definite status on the project, not
even the stage in which the film was in completion, if it was being done at all.
Frustrated, I asked him to return my money, which he failed to do so, despite
repeated promises that the film would be made. I sent a written demand to him
last September 2015 (a copy of which is attached hereto as Annex B, received
by the respondent), to no avail. In 2016 he made a written commitment to settle
the matter and even offered explanations on the status of the project, a copy of
which is attached hereto as Annex C;

4. Sometime last April 2017, I found out that the movie was already being shown in
schools, and even at selected cinemas in malls. I again confronted respondent
with this, but he failed to give a satisfactory reply as to when I would get my
earnings, or to just return my money;

5. Finally, I was forced to hire a lawyer who sent him a demand letter for the return
of my money last 15 May 2017, a copy of which is attached hereto, together with
a printout of the LBC tracking for said letter (under tracking number
126466552256), as Annex D and D-1. He has not responded to our latest
demand;

6. Respondent clearly used false pretenses and deceit in making it appear there
was a film project worthy of my investment, and such induced me to part with my
money. Now that he is confronted with the fruits of his lies, he can no longer
escape liability under the law, which has also resulted to my damage and
prejudice;

7. I am therefore filing this complaint for ESTAFA under Article 315 (1) (b) of the
Revised Penal Code against the respondent herein, and for whatever other legal
purposes this may serve.
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IN WITNESS WHEREOF, I have hereunto signed these presents on ______ 2017 at


Quezon City.

MA. ISABEL MACALINTAL y ANTILLON

Subscribed and sworn to before me this _________ 2017 in Quezon City.

I hereby certify that I have personally examined the affiant and am convinced she freely
and voluntarily executed her Complaint-Affidavit.

ASSISTANT CITY PROSECUTOR

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