REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

METROPOLITAN TRIAL COURT OF METRO MANILA
QUEZON CITY
BRANCH ______
TRUMED PHARMACEUTICALS
(owned and operated by Trumed Healthcare Corp.)
Represented by: Ms. Maribel Hernandez,
Plaintiff,
vs.

Civil Case No. _______________

For: Collection of Sum of Money

AIR21 Tuguegarao Branch,

Represented by Ms. Espie Bulseco,

Defendant.
X-------------------------------------------------------X
AFFIDAVIT OF CLAIM
I, Maribel Hernandez, of legal age, Filipino and a resident of No. 910
Caruncho, Compound, Palatiw, Pasig, after having been sworn to in accordance
with law, hereby depose and state that:
1.
I am the Credit and Collection Manager of Trumed Pharmaceuticals
(owned and operated by Trumed Healthcare Corp.), a corporation duly organized
and existing under and by virtue of the laws of the Philippines, with business address
at SGS Foundation Building, No. 1337 G. Araneta Avenue, Quezon City, where it
may be served with summons, orders, writs and other notices that may be issued by
this Honorable Court. As a Credit and Collection Manager, I was authorized to file this
action in behalf of Trumed Pharmaceuticals;
Copy of the Secretary's Certificate is hereto attached and marked in the
Statement of Claim as Annex A;
2.
Defendant AIR21 Tuguegarao Branch represented by Ms.
Espie Bulseco with business address at No.51 Mabini Street, Barangay 3, Centro
Tuguegarao, Cagayan, where it may be served with summons, orders, writs and
other notices that may be issued by this Honorable Court;

04/01/13 (Air21 Waybill No.

300017860686) for Sales Invoice No. 0414, 07/09/13 (Air21 Waybill No.
300018545570) for Sales Invoice No. 1457, 04/15/13 (Air21 Waybill No.
300017867531) for Sales Invoice No. 0549, pick-up the defendant ordered
3.

Sometime in the month of

and purchased from the plaintiff-corporation various medicines amounting to FORTY

THOUSAND FOUR HUNDRED TWENTY FIVE PESOS (P40,425.00).
4.
In payment for the products purchased, respondent issued and
delivered post-dated checks (PDCs), the details of which are as follows:

Bank

Check No.

Date

Amount

Reason for
Dishonor

BDO

209039

04/19/14

P20,425.00

ACCOUNT
CLOSED

BDO

209040

04/26/14

P20,000.00

Total:

ACCOUNT
CLOSED

P40,425.00

6.
Complainant-corporation deposited the above checks in its depository
bank (Philtrust Bank Grace Park Caloocan Branch) on their respective maturity
dates, but said checks were dishonored for reasons ACCOUNT CLOSED. Copies
of the checks with the reasons for their dishonor stamped thereon are attached and
marked in the Statement of Claim as Annexes B & C, respectively;
7.
On August 27, 2014, complainant-corporation through its collector, Mr.
Genesis Lip personally served copy of the herein demand letter dated August 26,
2014 addressed to Tyrone Jose Sison of Triple & Medman Drugstore located at Lot-7A, Blk. 19, Corner General Sandico & Visitacion Sts., Villa Rosario Subdivision
Angeles City, Pampanga. The said demand letter was personally received by Ms.
Felisitas S. Sison, mother of Tyrone Jose Sison, as evidenced by her signature over
her printed name appearing on the face of the Demand Letter dated August 26, 2014
specifically on page 1 thereof;
Copies of the demand letter dated August 26, 2014 and its Affidavit of
Service are attached hereto and marked in the Statement of Claim as Annexes D
and E, respectively,
8.
However, despite receipt of the demand letter and despite several
verbal follow-ups made, respondent failed and refused, and continuously fails and
refuses to pay and/or replace with cash the face value of the said bounced checks.
9.
The present case is not covered by the Barangay conciliation for the
reason that one of the parties is a corporation.
IN WITNESS WHEREOF, I have hereunto
____________________ in Quezon City, Philippines.

set

my

hand

this

MARIBEL HERNANDEZ
Affiant
SUBSCRIBED AND SWORN to before me this_____________________day
of
November 2014 , the affiant exhibited to me his Tax Identification with No. _201819-185-000 and his Social Security System ID with No. 33-5254260-8.
NOTARY PUBLIC
Doc. No. _______;
Page No. _______;
Book No. _______;
Series of 2014.