Republic of the Philippines )

City of Tacloban
) SS

AFFIDAVIT-COMPLAINT
Herein complainant, EDGARDO R. LIGON, Filipino, of legal age, married
with residence at 123 Palmera Drive, Brgy. 62-A, Sagkahan, Tacloban City, after
being sworn in accordance with law, hereby depose and state: THAT
1. Sometime on 28 January 2008 in Tacloban City, JOHN VELOSO, of
legal age, single and a resident of # 32 Real St., Brgy. 76, Fatima Village,
Tacloban City, executed an Acknowledgment of Debt in the amount of
P85,000.00 to herein complainant, payable in 10 equal monthly installment of
P8,500.00 per month in postdated checks; the original of the notarized
acknowledgment of debt is hereto attached and marked as Annex A.
2. Unfortunately, there were remaining five (5) postdated checks issued by
JOHN VELOSO which bounced or were dishonored by the drawee bank BPI
Tacloban Enage Branch, Tacloban City, when presented for payment, to wit:
BANK

Check No.

Date of Check

Amount

Date Presented

BPI
BPI
BPI
BPI
BPI

0127906
0127907
0127908
0127909
0127910

July 28, 2008

August 28, 2008
September 28, 2008
October 28, 2008
November 28, 2008

P 8,500.00
P 8,500.00
P 8,500.00
P 8,500.00
P 8,500.00

15 Dec 2008
15 Dec 2008
15 Dec 2008
15 Dec 2008
15 Dec 2008

TOTAL:

P42,500.00

Copies of the aforesaid checks, which were drawn against ACCOUNT

CLOSED with all prior endorsement and/or of endorsement guaranteed/check
return slips marked at the back of the aforenamed checks are hereto attached as
Annexes B, C, D, E and F respectively.
3. Demands, both oral and in writing, were subsequently made upon
JOHN VELOSO, to pay the amounts covered by the aforementioned checks plus
the penalties and surcharges until the debt is fully paid per Acknowledgment of
Debt. A copy of the FINAL DEMAND dated 17 November 2010 sent to JOHN
VELOSO and received by him or his authorized representative is hereto attached
and made part hereof as Annex G; the return card is likewise marked as
Annex G-1.
4. Unfortunately, to date, despite said demands, JOHN VELOSO failed to
pay the complainant the full amount of said checks or made arrangements with
the drawee bank for the payments in full within five (5) banking days from receipt
of the notice of dishonor, to the damage and prejudice of the complainant and in
violation of the provisions of Batas Pambansa Blg. 22;
5. By reason of the willful act of JOHN VELOSO, the complainant is
forced to institute the present action, incurring expenses for Attorneys fees in the
amount equivalent to 25% of the total amount due, exclusive of costs and
expenses of litigation but in no case less than P5,000.00, plus the payment of
interest of 10% for each check due from the time of default until full paid as
stipulated in said Acknowledgment of Debt.

6. I am executing this affidavit-complaint to attest to the veracity of the

foregoing facts and circumstances and for the purpose of filing a criminal
complaint against JOHN VELOSO who can be served with summons and other
processes at # 32 Real St., Brgy. 76, Fatima Village, Tacloban City, for violation
of Batas Pambansa Blg. 22.
IN WITNESS WHEREOF, I have hereunto set my hand this ___________
at Tacloban City, Philippines.
EDGARDO R. LIGON
Affiant
SUBSCRIBED AND SWORN to personally before me this _________ at
Tacloban City, by EDGARDO R. LIGON, who has satisfactorily proven his identity
to me through his SSS ID No. 06-0471467-9 and CTC No. 10110762 issued on
1-31-12 in Tacloban City respectively, and I HEREBY CERTIFY that I have
personally examined the affiant and I am personally convinced that she
voluntarily and knowingly executed this foregoing affidavit.

Doc. No. ____

Page No. ___
Book No. 62
SERIES OF 2012

ATTY. BARBETTE JOANNE M. BADOCDOC-REPOSAR

NC 2015-01-5, JAN. 5, 2016 , UNTIL DEC. 31, 2016
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