EPUBLIC 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 res
ident of c/o South Bank, Kauswagan Branch, Cagayan de Oro City, after having bee
n duly sworn to according to law hereby depose and say:
1. That I am the Loan Manager of South Bank, Kauswagan Branch, Cagayan de Oro Ci
ty. I am executing this affidavit in behalf of South Bank, being the complainant
herein.
2. In behalf of the said Rural Bank, I am filing a formal complaint for Estafa t
hru Falsification of Public Document and /or thru Forgery against respondent Api
pa G. Guro [hereinafter Respondent ], a resident of Vamenta, Carmen, Cagayan de Oro
City .
3. On October 31, 2007, Respondent using the name of, and misrepresenting hersel
f to be Doa Aiqa Macarambon-Bacsarpa, submitted a loan application, purportedly si
gned by the Spouses, by forging their signatures with South Bank, Kauswagan Bra
nch, Cagayan de Oro City amounting to PhP 5,000,000.00.
4. As security for the payment of the said loan, Respondent submitted as collate
ral thereof a parcel of land described in TCT No. T-178439 1 and executed a Real
Estate Mortgage over the said land in favor of South Bank. 2
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 the proceeds thereof
were delivered to the Respondent, receipt of which is evidenced by a manager s ch
eck issued by the bank and withdrawn by the Respondent. 3 Photocopy of the said
check is hereto attached as Annex C hereof;
6. On January 6, 2007, South Bank found out that respondent falsified and/or for
ged the above mentioned documents. It also found out that Respondent misrepresen
ted herself to be Doa Aiqa Macarambon-Bacsarpa when in truth and in fact the forme
r, as found by the bank, is Apipa G. Guro. 4 Respondent s real identity was discov
ered by the bank when one of it s employees identified her as an acquaintance as t
hey live in the same barangay and is personally known to her;
7. Respondent s 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 d
id not apply for a loan, much less mortgage the land covered by subject land tit
le in favor of South Bank;
8. The unlawful acts by Respondent caused damage and prejudice to South Bank in
the amount of PhP 5,000,000.00, the amount released to respondent as proceeds of
the loan, including interest of twelve percent (12%) per annum;
9. South Bank spent PhP 30,000.00 for attorney s fees for filing the complaint aff
idavit .
10. That I am executing this affidavit for and behalf of the South Bank, Kauswag
an, Cagayan de Oro City, being the Loan Manager thereof, to file a formal compla
int of Estafa through Falsification of Public Documents and/or through Forgery a
gainst Apipa Guro.
IN WITNESS WHEREOF, I have hereunto affixed my signature for and in beha
lf of the complainant South Bank Kauswagan, Cagayan de Oro City this 8th day of
December 2009, at Cagayan de Oro City.
Vincy Jane A. Polinar
Affiant
SUBSCRIBED and SWORN to before me this 8th day of December, 2009, at Cagayan de
Oro City. I hereby certify that I have personally examined the above-named affia
nt and that I am satisfied that the foregoing statements were given by him volun
tarily and of his own free will.

Azrifa A. Mamutuk
Associate Prosecution Attorney II