REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
ZAMBOANGA CITY

CHARLIE LABRADOR,
Complainant-Affiant,

-versus-

FREYA POODLE,
Respondent.

x----------------------------------x

COMPLAINT AFFIDAVIT

I, CHARLIE LABRADOR, of legal age, Filipino, single with

residential address at La Purisima Street, Zamboanga City, after
having been duly sworn to in accordance with the law hereby
depose and state:

1 That I am the Manager of China Bank Governor Lim

Branch, Zamboanga City. I am executing this affidavit in
behalf of China Bank, being the complainant therein;

2 In behalf of the said Bank, I am filing a formal complaint for

Estafa through Falsification of Public Documents and/or
through Forgery against respondent FREYA POODLE
[hereinafter Respondent], a resident of Pasonanca,
Zamboanga City;

3 On August 01, 2016, Respondent using the name of, and

misrepresenting herself to be MIMI HACHIKO, submitted
a loan application, purportedly signed by her, by forging her
signatures with China Bank Governor Lim Branch,
Zamboanga City, amounting to Php 10,000,000.00;

4 As security for the payment of the said loan, Respondent

submitted as collateral thereof a parcel of land described in
TCT No. T-000000, and executed a Real Estate Mortgage
over the said land in favor of China Bank;

5 On October 01, 2016, the loan application amounting to Ten

Million Pesos (Php 10,000,000.00) was approved by China
Bank and the proceeds thereof were delivered to the

Page 1 of 3
 Respondent. Receipt of which is evidenced by a managers
check issued by the bank and withdrawn by the
Respondent.

6 On November 01, 2016, China Bank found out that

respondent falsified and/or forged the above mentioned
documents. It also found out that respondent
misrepresented herself to be Mimi Hachiko when in truth
and in fact the former, as found by the bank is Freya Poodle.
Respondents real identity was discovered by the bank when
one of its employees identified her as an acquaintance as
they live in the same barangay and is personally known to
her;

7 Respondents unlawful acts were discovered by the bank

when the latter tried to collect from Hachiko who refused to
pay on the ground that she did not apply for a loan, much
less mortgage the land covered by subject land title in favor
of China Bank;

8 The unlawful acts of Respondent caused damage and

prejudice to China Bank in the amount of Php
10,000,000.00, the amount released to respondent as
proceeds of the loan, including interest of twelve percent
(12%) per annum;

9 China Bank spent Php 50,000.00 for attorneys fees for

filing the complaint affidavit;

AFFIANT FURTHER SAYETH NAUGHT.

IN WITNESS WHEREOF, I have hereunto affixed my

signature for and in behalf of the complainant China Bank
Governor Lim Branch, Zamboanga City, this 1st day of January
2017, at Zamboanga City, Philippines.

CHARLIE LABRADOR
Complainant-Affiant

SUBSCRIBED AND SWORN to before me on this 1 st day

of January 2017 at Zamboanga City, affiant exhibiting to me his
Postal I.D. issued at Zamboanga City on December 1, 2010.

Page 2 of 3
 LULU BLACK
Assistant
City Prosecutor

CERTIFICATION

I HEREBY CERTIFY that I have personally examined the

affiant-complainant and that I am satisfied that he voluntarily
executed and understood his Complaint-Affidavit.

LULU BLACK
Assistant
City Prosecutor

Page 3 of 3