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I, JUAN DESIDO, of legal age, married and a resident of 15 Alvero

St., Loyola Heights Subdivision, Quezon City, after having been duly sworn
to in accordance with law, do hereby depose and say that:

1. I am a businessman, native of Mataas na Kahoy, Batangas City

where I maintain my poultry and hog business under the name
of “Babuyan and Manukan in Juan” aside from my business I
also invest my money in other ventures where I lend money to
friends and distant relatives for 5-10% interest.

2. I accuse Mr. Melvin Santos, of legal age, Filipino, engaged in

the business of government construction projects, also a native of
Batangas City, for Violation of B.P. Blg. 22 committed under the following

3. Sometime on Nov 05, 2016, Mr. Melvin Santos, drew, issued

and delivered to me the following checks, in payment of an obligation, to

Bank Check No. Date Amount

Banco de Oro 0377963 011/05/16 Php 98,350.00

Banco de Oro 0357796 012/10/16 69,710.00
Banco de Oro 0357797 01/05/17 89,720.00
Banco de Oro 0377964 02/05/17 78,630.00
Banco de Oro 0377965 03/10/17 58,640.00
Banco de Oro 0377966 04/13/17 48,680.00
Banco de Oro 0377970 05/12/17 36,900.00
Total -------------- Php480,630.00

Copies of the said checks are hereto attached as Annexes “B”, “C”,
“D”, “E”, “F”, “G”, and “H”.

4. Upon presentment of the abovementioned checks on their

respective due dates at the Banco De Oro, Loyola Heights-Barkeley
Residences Branch, Quezon City, the said checks were all dishonored for
the reason of either “INSUFFICIENT Funds” or “ACCOUNT CLOSED”.

5. The loan was secured of a DEED OF SALE of a Ferrari Car which

would be valid when MR. MELVIN SANTOS fails to pay the obligation.

6. Several attempts to demand were made upon MR. MELVIN

SANTOS to inform him of the dishonor of the abovementioned checks and
directing him to pay but to our dismay we did not receive any reply from the
above-mentioned name.

7. Due to the fact that MR. MELVIN SANTOS is nowhere to be found,

I went to the Local Government Office to hope in the recovering of my
money and ask a lien on the money to be paid to Melvin in connection with
the business venture he engaged with the government but the “Notice of
bidding Award” he presented to me upon lending him money was spurious
and the project of the government was in fact shelved by the government
for lack of funding.

8. The deed of sale of the Ferrari Car he gave me as a security upon

the loan was long sold and registered in the name of Kevin Corona. Thus, I
am compelled to constrained the services of a lawyer who sent a demand
letter informing him of the dishonor of the checks subject matter of this
complaint and demanding full payment of the face value of the checks.
Copy of the demand letter sent by our lawyer is hereto attached as Annex

9. I am executing this Affidavit of Complaint to attest to the truth of

all the foregoing facts and for the purpose of instituting a criminal complaint
against MR. MELVIN SANTOS for Violation of B.P. Blg. 22 and/or such
other crimes appropriate under the premises.

IN WITNESS WHEREOF, I have hereunto affixed my signature this

_____ day of January 2017 in the City of Manila.

SUBSCRIBED AND SWORN to before me this ____ day of January
2017, in the City of Manila.

Assistant City Prosecutor


This is to certify that I have personally examined the affiant and that I
am satisfied that she voluntarily executed her Affidavit of Complaint and
that she has read and understood the contents thereof and that the same
are all true and correct to the best of her personal knowledge.

Assistant City Prosecutor

Code: Affidavit of Complaint (BR Chua vs. Efren Marquez)