REPUBLIC OF THE PHILIPPINES )

PROVINCE OF PAMPANGA )
CITY OF SAN FERNANDO ) S.S.

AFFIDAVIT OF COMPLAINANT
I, NOWELYN N. ARROZAL, representative of Castillo Lending Inc., of legal age, Filipino,
single, and a resident of No. 34 Purok 5, Brgy. Juliana, San Fernando, Pampanga, after being
sworn according to law, hereby depose and state that:

1. That I am the representative of CASTILLO LENDING INC.,(CLI) a lending

institution duly organized and existing under the Laws of the Philippines, having its
principal office at Ground Floor, Unit A1, GAN Building, Brgy., San Nicolas, San
Fernando, Pampanga; Hereto attached as ANNEX "A" is the Secretary's
Certificate incorporating the Board Resolution passed to that effect.

2. That I, as representative of Castillo Lending Inc.,(CLI), am filing a small claims

case against defendant EDGAR D. DIZON Filipino citizens, A legal age, and PNP
pensioners with postal and residence address at 1744 MACTAN ST.,CMR
ANGELES CITY where he may be served with summons and other court process.
As evidence, a copy of EDGAR D. DIZON’S information sheet and his
identification card are attached herewith and marked as ANNEX “B” and ANNEX
”B-1”.

3. That on May 05 , 2014, defendant EDGAR D. DIZON borrowed a sum of money

from Castillo Lending Inc. in the total amount of Twelve Thousand Pesos Only
(Php 12,000) with an interest rate of 5% per month and executed a promissory
note. As evidence, a photocopy of the promissory note is attached herewith and
marked as ANNEX”C ‘’.

4. That on May 20, 2014 the Defendant demands for additional loan amounting to Six
Thousand Six Hundred Pesos Only (P 6,600) .As evidence, a photocopy of the
promissory note is attached herewith and marked as ANNEX “D”.

5. That same scenario of additional loan repeats several times. As evidence,

photocopies of Promissory notes are herewith attached and marked respectively
as ANNEXES ‘’E’’, “E-1”, “E-2”, “E-3”,” E-4”, “E-5”, “E-6”, “E-7”, “E-8”, “E-9”,
“E-10”,” E-11”, “E-12”,” E-13” and “E-14”.

6. That defendant also requested from our office to send additional loans on January
20, 2015 amounting to Twenty Two Thousand Pesos Only (Php 22,000) with
Cebuana control number P64FA2ERAL, March 27, 2015 amounting to Three
Thousand Three Hundred Pesos Only(Php 3,300) with Cebuana control number
.P64FE9E1AK, August 18, 2015 with Cebuana control number P64FLYEJC7
amounting Eight Thousand Pesos Only(Php 8,000) and on December 17,2015
amounting Ten Thousand Pesos Only (Php 10,000) As evidence, we attached a
photocopy of the promissory notes dated January 30, 2015, , March 27, 2015,
August 18, 2015 and December 17, 2015 marked respectively as “ E-11”, “E-
12”,” E-13” and “E-14”.

7. That as evidence that defendant received the money, I attached herewith, a

photocopy of the receipts from CEBUANA and Certification issued by Cebuana
marked respectively as ANNEXES “F” ,‘’F-1’’, “F-2“ ,“F-3” AND “G”, “G-1” ,
“G-2”.

8. That defendant EDGAR D. DIZON also executed an AFFIDAVIT OF

UNDERTAKING allowing our office personnel to withdraw his monthly pension
 and promises that he will not declare as lost his ATM CARD. As evidence, a
photocopy of the affidavit of undertaking is attached herewith and marked as
ANNEX “H”.

9. That defendant executed a Special Power of Attorney authorizing Mr. Emilio P.

Castillo, president of CLI, to withdraw his monthly pension from LANDBANK every
payday until fully paid. As evidence, a photocopy of the Special Power of Attorney
is herewith attached and marked as ANNEX ” I ”.

10. That sometime on APRIL 2016, Plaintiff went to the bank to collect the monthly
amortization due from defendant's bank account.

11. That when defendant’s ATM card was inserted into the Land Bank Machine, it was
retained by the machine with the advisory receipt stating “Invalid Card.”

12. That it appeared that the defendant reported to the LBP that he had lost his ATM
card. The said report enabled him to withdraw his salary over the counter and led
to the issuance of a new ATM card in his favor.

13. That because of that malicious and baseless report, Plaintiff was not able to
withdraw the amount due on defendant’s loan obligation. Thus, plaintiff verbally
demanded an explanation from defendant and his wife, but they did not answer
any phone calls and refuse to show up when plaintiff’s representatives went to
their house.

14. That as shown in the attached promissory notes and statement of account, the
indebtedness of the defendants has become due and demandable. As evidence, a
photocopy of the Statement of account is herewith attached and marked as
ANNEX” J”.

15. That despite plaintiff's repeated demands, both written and verbal, defendants
failed, neglected and refused to fulfill his obligations without just and valid grounds
to the continued damage and prejudice of plaintiff. As evidence, photocopy of the
demand letter and registry return card are herewith attached and marked
respectively as ANNEX "K", ANNEX “K-1”,

16. That I am executing this affidavit to attest to the truth of the foregoing statements.

AFFIANT FURTHER SAYETH NAUGHT.

IN WITNESS WHEREOF, I have hereunto set my hand this _____________________at San

Fernando, Pampanga.

NOWELYN N. ARROZAL
AFFIANT

SUBCRIBED AND SWORN to before me this ____th day of ___________________, affiant

exhibited to me her UMID NO.CRN0111-3554806-7 issued at San Fernando, Pampanga.

Doc. No. ______;

Page No.______;
Book No.______;
Series of 2019.