COMPLAINT AFFIDAVIT FOR VIOLATION OF BP 22

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE

OFFICE OF THE CITY PROSECUTOR

PARAÑAQUE CITY

KARLA PETRINA ASSISTIO

Complainant,

I.S. NO. XV-12-INV-15-F-01378

For : VIOLATION OF B.P. 22

(2 COUNTS)

-versus-

ANNA ROSARIO ROJAS

Respondent,
x------------------------------------------------x

COMPLAINT-AFFIDAVIT

   I, KARLA PETRINA ASSISTIO, a Filipino, of legal age, with office address at 23 Kanlaon St, Cor. M. Cuenco, Bgy. Sto. Domingo Quezon City, after having been duly sworn in accordance with law, do hereby depose and state that:

1. I am the owner of a Laundromat “Summa con Laundry” in Banawe Quezon City. It is a flourishing business;

2. Anna Rosario Rojas, is my friend, Flipino, of legal age, owner of a single proprietorship business funeral parlor named “Libing Things” with a business address at 1125 J. Vargas Avenue, Scout Fuentebella St. Tomas Morato, Quezon City;

3. Because Anna's funeral parlor is not doing so well, on August 23,2019, Anna sought my help by borrowing money in the amount of Php 500,000 to augment her losses;

4. Anna and I executed a loan agreement whereby Anna would pay me back the total sum after 6 months. For this purpose, Anna tendered a post-dated check to me, drawn from BDO Banawe Branch  with Check No. 1103452789, in the amount of ,PHP 500,000.00 dated February 23. 2020;

5. Photocopy of the said check is hereto attached and marked as "Annex A";

6. Consequently, when I presented the check to the bank on its due date, the same was dishonored due to (DRAWN AGAINST INSUFFICIENCY OF FUNDS) “DAIF”;

7. I immediately called Anna to inform her that the check bounced. Anna in turn committed to issue another check which she assured would be a good check;

8. On February 26, 2020. Anna issued to me as payment another check, drawn from BDO Banawe Branch with Check No. 1145237894 and worth Php 500,000.00;

9. Photocopy of the said check is hereto attached and marked as "Annex B";

10. However, when I went to the bank to encash the check the same was dishonored this time due to “ACCOUNT CLOSED”;

11. Furious and disappointed with her for toying with my trust, I sent a demand letter dated March 1, 2020 to Anna notifying her of the bounced checks she issued;

12. Photocopy of the said demand letter is hereto attached and marked as "Annex C";

13 Anna replied and said that she would pay her obligation in cash but since then, she intentionally and maliciously evaded her obligations;

14. As a result, the Complainant was compelled to engage the services og the undersigned counsel at an agreed amount equivalent to 25% as Attorney's Fees;

15. I am executing this affidavit to attest to the truth of the foregoing facts and for the purpose of charging ANNA ROSARIO ROJAS for violation of the provisions of BATAS PAMBANSA BLG. 22 for 2 counts which includes the original and replacement checks issued by Anna.

  IN WITNESS WHEREOF, I have hereto set my hand this 15th of March 2020 in Parañaque City, Philippines.

KARLA PETRINA ASSISTIO

Affiant

  SUBSCRIBED AND SWORN to before me this 15th of March 2016 at Parañaque City Philippines and I FURTHER CERTIFY that I have personally examined the affiant and I am satisfied that she has read and personally understood the contents of her foregoing "Complaint-Affidavit".

RAPHAEL S. SUYO

Asst. City Prosecutor

Roll No. 56918

IBP No.1004691/01-08-9/PPLM

PTR No. 0513159/01-06-19/Parañaque

MCLE Compliance No.V-0010494/09-16-15

Issued on April 20, 2005