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REPUBLIC OF THE
PHILIPPINES)
CITY OF BACOLOD ) s.s.

COMPLAINT-AFFIDAVIT

I, Otto Potato, Filipino, of legal age, single, and a resident of

Bacolod City, Philippines, after being sworn to in accordance with
law, depose and state:

That I know the person of Claudia Jungoy, who is a resident of

No. 823 Domingo Street, Bacolod City, Philippines;

That sometime in the morning of October 2008, at 812

Mansion, San Doimingo, Bacolod City, Philippines, the said Claudia
Jungoy issued in my favor a BPI Check No. 21365 in the amount of P
200,000 as supposed payment for the loan accommodation of
P180,000, which I have extended to her;

That the said check is drawn against the account of the said
Claudia Jungoy at BPI with Account No. 0025-2200-28;

That at the time the said Claudia Jungoy issued the delivered
the said check to me, she made the assurance and representation
that the said check is a good check and would be covered by
sufficient funds when presented for payment;

However, when the above-mentioned check was deposited, the

same was dishonored and returned by the bank on the ground that
the same was drawn against a "CLOSED ACCOUNT".A true and
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faithful machine reproduction of the said check is hereto attached as

Annex “A”;

As such, I immediately notified said Claudia Jungoy of the

dishonor and return of the said check and demanded from her that
she make good the said check within five days (5) days from receipt
thereof. A true and faithful machine reproduction of my demand letter
to her is hereto attached as Annex "B"

When said Claudia Jungoy failed to heed my demands, I

endorsed the said check to my legal counsel who immediately sent a
formal demand letter through registered mail with return card on
November 20, 2018, which was received by the said Claudia Jungoy
on November 28, 2018. As of date however, Claudia Jungoy has
unjustifiably ignored all these demands to pay the said account
and/or to redeem the said returned check. A true and faithful machine
reproduction of my demand letter to her is hereto attached as Annex
“C"

I am therefore executing this Complaint-Affidavit in support of

the charges for Violation of Batas Pambansa Bilang 22 against the
said Claudia Jungoy, who may be served with subpoena and other
processes of this Honorable Office at her last known address at No.
823 Domingo Street, Bacolod City, Philippines;

IN WITNESS WHEREOF, I have hereunto set my hand this 5th

day of December, 2018 at Bacolod City, Philippines.

_________________
Otto Potato
Affiant-Complainant
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SUBSCRIBED AND SWORN to before me this 5th day of

December, 2018 at San Juan, Philippines.

____________________________
SALVINO KRISTI S. KALALANG
Office of the City Prosecutor

CERTIFICATION

I hereby certify that I have examined the Affiant and that I am

fully satisfied that he has voluntarily executed and understood the
contents of his Complaint-Affidavit.

____________________________
SALVINO KRISTI S. KALALANG
Office of the City Prosecutor