Complaint Alleging

Fraud Securities with

Investment Contracts
And Investments Scam
COMPLAINT – AFFIDAVIT

COMES NOW the complainant, by the undersigned attorney-in-fact, and to

this Honorable Commission, respectfully alleges and states as follows:

1. That complainant, ARRABEL QUEENIE C. VALENZUELA is of

legal age, Filipino citizen and resident of No.33 5TH West Crame, Brgy. West
Crame, San Juan City where he may be served with summons;

2. That respondent corporation EMMRJ LOAN CONSULTANCY

CORPORATION (herein after referred to as “EMMRJ LOAN” for brevity) is a
domestic stock corporation registered with Securities and Exchange Commission
on April 24, 2017 with S.E.C. No. CS201713579 and with principal office address
located at ________________________________________________________
where it may be served with summons;

3. That respondent ELAINE JOY SANTOS is the President and

Operations Head of the respondent corporation. She is also of legal age, Filipino
citizen and a resident of _________________________________ where he may be
served with summons;

4. That on year 2018, complainant purchased securities amounting to

TWO MILLION PESOS (Php2,000,000.00) from respondent shares of stock in
EMMRJ LOAN CONSULTANCY CORPORATION and also paid a series of 7
investment with a 6 month period per investment contract amounting TWO
MILLION FOUR HUNDRED FOURTEEN THOUSAND AND EIGHT
HUNDRED EIGHTY PESOS (Php 2,414,880.00)

5. That, said purchased securities and paid investments, are evidenced

by a receipts, stock certificates, co-ownership agreements and investment
agreements signed by respondent ELAINE JOY SANTOS as President and on
behalf of and for EMMRJ LOAN CONSULTANCY CORPORATION, (a copy of
which is hereto attached as “annexes”) and made integral part of this complaint;

6. That, according to the contents of the co-ownership agreement made

and executed by respondent to the complainant in relation to the purchased made to
said securities, the respondent corporation will monthly pay the complainant 20%
percent of its purchased securities equivalent to FOUR HUNDRED THOUSAND
PESOS (Php400,000.00) as its monthly profits earned being a Co-Owner of
EMMRJ LOAN, Monthly allowances worth of THIRTY THOUSAND PESOS
(Php 30,000.00), Mid year and year end bonuses and Twenty percent (20%) of
EMMRJ LOAN net annual income as annual dividend of complainant securities.

7. That the total amount of above stated twenty percent monthly profits
of complainant as Co – Owner of EMMRJ LOAN is FOUR MILLION EIGHT
HUNDRED THOUSAND (Php 4,800,000.00) computed as Php400,000 (per
month as twenty percent net profit) x 12 consecutive months in accordance to
respective Co-Ownership Agreement;

8. That the total amount of above stated monthly allowances of

complainant as Co-Owner of EMMRJ LOAN is THREE HUNDRED SIXTY
THOUSAND PESOS computed as THIRTY THOUSAND PESOS (Php
30,000.000) x 12 consecutive months in accordance also to respective Co-
Ownership Agreement;

9. That the amount of Mid year and year end Bonus is

____________________________________ in accordance also to respective Co-
Ownership Agreement;

10. That the amount of annual dividend collectively by the complainant

to EMMRJ LOAN as her twenty percent shares in the annual net income of the
respondent corporation based on their latest submitted and /or filed Financial
Statement (FS) with this Commission is
____________________________________________ in accordance also to
respective Co-Ownership Agreement. (a photocopy of the said Financial Statement
is hereto attached as annex ____)

11. That in addition to the total obligations to pay of by herein

respondents to the complainant as penalties in their failure to pay in time
“monthly” as agreed in above stated Co-Ownership Agreement is
________________________________________________________.

12. In relation to the above stated contracts issued and executed by herein
respondents to complainant is the “Investment Agreements” (a phoyocopy of the
said Agreements are hereto attached as Annex ______ to Annex _________) made
to be an integral part of this complaint;

13. That, according to the said investment agreement made and executed
by herein respondents to complainant upon the maturity date of the investments
paid by complainant to herein respondents. EMMRJ LOAN will pay the
complainant a Twenty percent (20%) of its principal amount invested which total
amount is FOUR HUNDRED EIGHTY TWO THOUSAND NINE HUNDRED
SEVENTY SIX PESOS (Php 482,976.00);

14. That the total amount of twenty percent monthly net profit based on
the total principal amount paid in the investments made is TWO MILLION EIGHT
HUNDRED NINETY SEVEN THOUSAND PESOS AND EIGHT HUNDRED
FIFTY SIX (Php 2,897,856.00) computed as FOUR HUNDRED EIGHTY TWO
THOUSAND NINE HUNDRED SEVENTY SIX PESOS (Php 482,976.00 x Six
(6) consecutive months in accordance also to respective “Investment Agreement;

15. That in failure to pay monthly in six consecutive months and in

addition to the total amount of net profits, the total amount of the penalties is
_________________________________________________ in accordance also to
respective “Investment Agreement

16. That, the respondents just issued a post dated cheques to complainant
as payments of their obligations and dues to the complainant;

17. But the said post dated cheques issued and given by herein
respondents to the complainant surprisingly all bounced;

18. Disappointedly, all the agreements made in the said above contracts
both in Co-Ownership Agreement and Investment Agreement breeched by herein
respondents in their failure to pay of all their obligations and dues to the
complainant.

19. That due to the above instances, the complainant insisted and demand
the herein respondent to refund all the payments she made relatively in securities
and series of 7 investments amounting to the total amount of FOUR MILLION
FOUR HUNDRED FOURTEEN THOUSAND AND EIGHT HUNDRED
EIGHTY THOUSAND PESOS (Php 4,414,880.00) as her principal amount paid
accordingly to the above Co-Ownership Agreement and Investments Agreement
made.

20. But despite of repeated demands, both written and oral, respondents
has failed and refused to pay the refund of the payments made to securities and
payments made to a series of 7 investments as above stated;

21. That due to the unjust and unlawful act of herein respondents to
comply with the said demands to pay of all their obligations and dues and also the
computed penalties as agreed in their executed contracts/agreements, the
complainant was compelled to institute this action engaging the services of
attorney-in-fact in the amount of Php___________________________ plus the
amount cost and filing fees of this foregoing and/or complaint-petition is
Php_______________________________________

WHEREFORE, it is respectfully prayed that judgment be rendered against

the respondents to pay the complainant the all the sum of
______________________ plus interest of 12% from the date of the instrument
until full amount is payed and the attorney-in-fact service/fees in the amount of
_____________________ and costs and filing fees of the suit.

Other equitable reliefs are likewise prayed for.

___________________, 2019, _______________ City.

JASMIN VENIEGAS CO
Attorney-in-Fact for Complainant
P10a P2 B17 L1
Bagong Silang Caloocan City
Address

COMPLAINT
(SEVERAL CAUSES OF ACTION)

Complainant Alleges:
First Cause of Action
1. That Complainant ARRABEL QUEENIE C. VALENZUELA is a resident
of No. 33 th West Crame, Brgy. West Crame San Juan City, and
 2. That Respondent ELAINE JOY SANTOS is a resident of
________________________________________ where he may be served
with summons;

3. That on _______________________________, complainant executed and

delivered to respondent a promissory note, in the following words and
figures, to wit:

4. That defendant has not paid promissory note, nor any part thereof or
interest thereon;

As Second Cause of Action:

1. Complainant hereby incorporates the allegations of paragraph 1 of the first
cause of action;

2. That on the _____________________, complainant executed and delivered to

the respondent his promissory note in the following words and figures, to wit:
(insert copy of promissory note)

2. Same as paragraph 3 of the first cause of action)

WHEREFORE, it is respectfully prayed that judgment be rendered in favor

of Complainant and against respondent for the sum of (the total amount of the
promissory notes) with interest at the rate of six percentum per annum on each of
the aforesaid notes, until paid; interest at the legal rate on the interest due from the
time of the filing of the complaint and attorney’s fees plus costs.
 COMPLAINANT, further prays for such other relief as this Honorable
Commission may deem just and equitable in the premises.
Manila, Philippines, _____________________, 2019

JASMIN VENIEGAS CO
Attorney-in-Fact for Complainant
P10a P2 B17 L1
Bagong Silang Caloocan City
Address