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REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE

OFFICE OF THE PROVINCIAL PROSECUTOR


PROVINCE OF CAVITE
GEN. TRIAS, CAVITE

JOSEPH WILLIAM SMITH y FELICIANO


Complainant,
-versus-

I.S.

No.

IV-03-INV-15E-

1530
For: Estafa
MICHAEL HANOPOL y CARBON
Respondent.
xx----------------------------xx

COMPLAINT-AFFIDAVIT
I, JOSEPH WILLIAM SMITH y FELICIANO, 30 years old, Filipino,
with residence at 2222 Brgy. Manggahan, Gen. Trias, Cavite, do
hereby depose and state:
1. That I am the Owner of ABC Building, a commercial building
with stalls for rent located at 1111 Heneral Luna St., Brgy.
Pinyahan, Gen. Trias, Cavite.
2. That after having duly sworn to in accordance with law, I do
hereby accuse MICHAEL HANOPOL y CARBON, tenant of
Stall D of ABC Building, with postal address at 3333 Brgy.
Langkaan, Gen. Trias, Cavite, of the complex crime of ESTAFA
WITH ABUSE OF CONFIDENCE under Article 315, par. 1(b) of
the Revised Penal Code.
3. That on December 13, 2013, the accused started to occupy
Stall D of Capstone Building for one year with monthly rental
payment of Twenty Thousand (PHP 20,000.00) Pesos Only, as
evidenced by a lease contract. Starting February 2014 until
December 2014, the accused defaulted to pay his monthly
rental payment.
4. That on January 12, 2015, the accused executed a promissory
note at Stall D of ABC Building, wherein he promised to pay his
arrears on rental payment for the months of January to
December 2014, amounting to Eighty Thousand (Php
220,000.00) Pesos on March 31, 2015.
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5. That on March 31, 2015, I did not receive any form of


communication from him stating that he will settle the whole
amount. I called his mobile phone on April 1, 2015 but his
mobile cannot be reached. On April 2, 2015, the other tenants
in the same building told me that the accused together with 2
male fellow gathered all his belongings and valuables on the
night of April 1, 2015 without my consent;
6. I decided to seek the assistance of Baranggay Buenavista
wherein he was sent three (3) invitations for mediation of my
alleged complaint but he did not show up on all three
instances;
7. Upon his third failure to attend the mediation proceedings, the
Baranggay Captain endorsed my complaint to the Local PNP of
Gen. Trias, Cavite. The Local PNP sent him an invitation for
mediation and clarification but he also failed to show up
because he already moved from his residence.

TO THE TRUTH OF THE FOREGOING, I have signed this


Complaint-Affidavit on May 22, 2015.
JOSEPH WILLIAM SMITH y FELICIANO
Affiant
SUBSCRIBED and SWORN TO BEFORE ME, this 29th day of
January in Gen. Trias Cavite.
Jemuel Bayot
Investigating Prosecutor

CERTIFICATION
I hereby certify that I have personally examined the Affiant
and that I am satisfied that she voluntarily executed and understood
her affidavit.

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Jemuel Bayot
Investigating Prosecutor

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