Affidavit of Complaint BP 22 BASA

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REPUBLIC OF THE PHILIPPINES)

MANDALUYONG CITY…………) S.S.

COMPLAINT-AFFIDAVIT

I, Ms. Yohla Gabo Tanigue, of legal age, Filipino, and with


the residence at #59 8th Avenue, Corner Main Avenue, Cubao
Quezon City, after having sworn to under oath in accordance with
the law do hereby deposes and states that:

1. I am charging Ms. ANGELICA K. CARREON, for the


crime of Two (2) counts of Estafa through issuance of
Bouncing Checks and two (2) counts of violation of Batas
Pambansabilang 22 (Anti-Bouncing Check Law) and for
such other crimes as applicable under the following
circumstances:

a. MS. ANGELICA as known to me, is employed at


INQUIRER.NET, as Operations Head, Special Projects,
whose known address is at c/o 3rd Floor, Media
Resources Plaza Building, Mola Street, Corner Pasong
Tirad, Makati City, where summons and notices may
be served for Estafa and for violation of BP 22;

b. Sometime____________, Ms. ANGELICA and I had a


conversation regarding a perceived project in their
company, which was awarded to her by her boss. She
told and informed me that we can make good profits
out of the said project, insisted me to invest theirn, but
I was having a reservation at that time;

c. Since I have second thoughts and reservation of


investing money with the said project, Ms. ANGELICA
made a suggestion if she could barrow a money
instead, with an interest rate of 10% per month, for
reasons that she will be the one who will invest with
the said project in their company;

d. On August 10, 2018, because of her sweet talks, false


pretenses, machinations, and deceit, and out of trust
and confidence, she was able to collect money from
me amounting to One Hundred Thaousand Pesos (Php
100, 000.00) through a check that I issued under her
name, which was also encashed by Ms. ANGELICA on
the same day;

e. That as we agreed the said money I lend to her was


particulary be used to the said project, bearing in mind
that she represented herself to have power and
influence over the said company’s directors and
officers who had reposed trust and confidence in her,
with which the said perceived project will have great
profit advantageous to us;

f. That as a security of payment on the loan contracted,


Ms. ANGELICA issued post dated checks (PS Bank Boni
Avenue, Mandaluyong City Branch), knowing fully well
that the said checks had no funds in the bank, or were
not sufficient to cover the amount of the checks she
issued as follows:

e.1. Particulars of the Post Dated Checks issued


simultaneously; (Annexes “A” to “B” hereof)

Checks Particulars
Bank Date Acct. Nos. Check Amount Reason
No. for
dishonor
PSBANK 10-17- 131330- 0079329 P45, Account
2018 00005-1 000.00 Closed
PSBANK 10-17- 131330- 0079331 P40, Account
2018 00005-1 000.00 Closed

g. On the date of the abovementioned checks, I went to


PSBANK Boni Avenue, Mandaluyong City to present
and encash the same, and to my dismay, I was
informed by the drawee bank that the checks were
dishonored due to closed accounts as shown by the
stamp markings in the gererated copy of the checks
on Annex “A” and “B”;
h. Demands and Notices of Dishonor of Checks, both oral
and written were made to Ms. ANGELICA, but were all
in vain. Copy of the demands and notice of Dishonored
Checks which was served upon her through his known
address and received by authorized representative of
sufficient age and discretion is hereto attached and
marked as Annexex “C” to “F” hereof;
i. To date, Ms. ANGELICA, failed and deliberately refused
to pay the value of the checks that she had issued in
connection thereto or replace the same after demand;

2. I am executing this Complaint-Affidavit to attest the truth


of the foregoing and to support the filing of criminal
complaints for Estafa under the Revised Penal Code and
Violation of BP 22 (anti bouncing checks law) against the
RESPONDENT and for such other additional crime as may
be applicable under the facts and circumstances above-
stated.

IN WITNESS WHEREOF, I have set my hand this ___th day


of __________________, at.

Ms. Yohla Gabo Tanigue


Affiant

SUBSCRIBED AND SWORN TO before me this ____________,


in Mandaluyong City, Philippines. I hereby certify that I personally
examined the affiant and I am convinced that she voluntarily
executed and understood the contents of her Complaint Affidavit.

Assistant City Prosecutor

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