REPUBLIC OF THE PHILIPPINES)

C I T Y O F CAGAYAN DE ORO ) S.S.

COMPLAINT-AFFIDAVIT
That I, Vincy Jane A. Polinar, of legal age, married, Filipino and a residentof c/o South
Bank, Kauswagan Branch, Cagayan de Oro City, after having beenduly sworn to
according to law hereby depose and say:
1. That I am the Loan Manager of South Bank, Kauswagan Branch, Cagayande
Oro City. I am executing this affidavit in behalf of South Bank, beingthe
complainant herein.
2. In behalf of the said Rural Bank, I am filing a formal complaint for Estafa thru
Falsification of Public Document and /or thru Forgery against respondent Apipa
G. Guro [hereinafter Respondent],a resident of Vamenta, Carmen, Cagayan de
Oro City .
3. On October 31, 2007, Respondent using the name of, and
misrepresentingherself to be Doa Aiqa Macarambon-Bacsarpa, submitted a
loanapplication, purportedly signed by the Spouses, by forging their
signatureswith South Bank, Kauswagan Branch, Cagayan de Oro City amounting
toPhP 5,000,000.00.
4. As security for the payment of the said loan, Respondent submitted ascollateral
thereof a parcel of land described in TCT No. T-1784391and executed a Real
Estate Mortgage over the said land in favor of South Bank.
5. On December 6, 2007, the loan application amounting to Philippine Pesos:Five
Million (PHP 5,000,000.00) was approved by South Bank and theproceeds
thereof were delivered to the Respondent, receipt of which is evidenced by a
managers check issued by the bank and withdrawn by the Respondent.
Photocopy of the said check is hereto attached as Annex Chereof;
6. On January 6, 2007, South Bank found out that respondent falsified and/orforged
the above mentioned documents. It also found out that Respondent
misrepresented herself to be Doa Aiqa Macarambon-Bacsarpa when in truth
and in fact the former, as found by the bank, is Apipa G. Guro. Respondents real
identity was discovered by the bank when one of its employees identified her as
an acquaintance as they live in the same barangay and is personally known to
her;
7. Respondents unlawful acts were discovered by the bank when the latter tried to
collect from the Spouses Bacsarpas who refused to pay on the ground that they
did not apply for a loan, much less mortgage the land covered by subject land
title in favor of South Bank;

8. The unlawful acts by Respondent caused damage and prejudice to SouthBank in

the amount of PhP 5,000,000.00, the amount released torespondent as proceeds
of the loan, including interest of twelve percent(12%) per annum;
9. South Bank spent PhP 30,000.00 for attorneys fees for filing the complaint
affidavit.
10. That I am executing this affidavit for and behalf of the SouthBank, Kauswagan,
Cagayan de Oro City, being the Loan Manager thereof to file a formal complaint
of Estafa through Falsification of Public Documents and/or through Forgery
against Apipa Guro.

IN WITNESS WHEREOF, I have hereunto affixed my signature for and inbehalf of the
complainant South Bank Kauswagan, Cagayan de Oro City this 8
th
day of December 2009, at Cagayan de Oro City.
Vincy Jane A. Polinar
AffiantSUBSCRIBED and SWORN to before me this 8
th
day of December, 2009, atCagayan de Oro City. I hereby certify that I have personally
examined the above-named affiant and that I am satisfied that the foregoing statements
were given byhim voluntarily and of his own free will.
Azrifa A. Mamutuk
Associate Prosecution Attorney II