Republic of the Philippines

DEPARTMENT OF JUSTICE
National Prosecutorial Service
OFFICE OF THE CITY PROSECUTOR
Hall of Justice, Santiago City

VINCENT BACANI PUA,

Complainant,

-versus- I.S. No.__________________

For Estafa

ANTHONY DE GUZMAN INOCENCIO

Respondent
x---------------------------------------------x

AFFIDAVIT-COMPLAINT

I, Vincent Bacani Pua, 25 years old, single, Filipino citizen

and a resident of Mazda Street, St.James, Batal, Santiago City, after
having duly sworn to in accordance with law do hereby depose and
say :

1. That I am formally charging respondent ANTHONY DE

GUZMAN INOCENCIO,38 years old, married, Filipino citizen and a
resident of Sitio Pulo, Barangay Dolores, Capas, Tarlac for the crime
of ESTAFA penalized under Article 315 of the Revised Penal Code,
committed as follows, to wit:

a) That I personally known the respondent also known as

Anjoe for almost three(3) years as a businessman and a former
factory worker for six(6) years in South Korea,

b) That respondent is the sole proprietor of Cagayan Valley

Korean Language Tutorial Center(CVKLTC for short) located at 2 nd
floor, Bustamante Building, Maharlika Highway, Victory Norte,
Santiago City,
 c) That CVKLTC and other branches situated in Region 2 is
engaged in business in teaching Korean language to any person
who is interested to learn the same for a fee,

d) That I and my girlfriend trusted the respondent wholly and

without any reservation particularly in monetary dealings because
the respondent himself personally gave backpay and allowance to
my girlfriend when she left and worked to South Korea as factory
worker,

e) Sometime during the month of February 2017, I heard an

information that the respondent is conveying the management and
affairs of CVKLTC and other branches in Region 2 because
according to the respondent, he wanted to establish tutorial center
within Metro Manila,

f) But the truth of the matter is that CVKLTC and other

branches in Region 2 incurred unpaid tax liabilities( tax maped)
and the respondent failed to settle its obligations,

g) During the time when my girlfriend was staying here, she

manifested her desire to personally manage the operation of
CVKLTC in order to support and facilitate the job processing to
work abroad for those students that are enrolled therein,

h) At that instance, my girlfriend seek the assistance of her

friend and former officemate named Joyvin Cuaresma to convince
the respondent to sell to her the CVKLTC Santiago Branch,

i) That on 22 February 2017, my girlfriend told me that she

had already talked with the respondent regarding her intention to
take over the CVKLTC Santiago Branch which the latter agreed in
the amount of Two Hundred Thousand Pesos(Php200,000.00),

j) On the same date, my girlfriend also told me that the said

establishment was co-shared by Angie Bulan(Angie for brevity)
because according to respondent, a One hundred Thousand
Pesos(Php100,000.00) was loaned by Angie in his favor,

k) That the respondent assured my girlfriend that the

agreement between the respondent and Angie pertaining to rights
exercised by the latter in managing CVKLTC would cease once the
One hundred Thousand Pesos(Php100,000.00) was returned back
to Angie,
 l) With such assurance and guarantee given by the
respondent, my girlfriend was convinced and agreed to pay the
amount of Two Hundred Thousand Pesos(Php200,000.00) to the
respondent as consideration to take over the management and
affairs of CVKLTC,

m) On 24 February 2017, the respondent asked for an initial

amount of One hundred Thousand Pesos(Php100,000.00) because
he is badly in need of money,

n) On 25 February 2017, I gave Fifty Thousand

Pesos(Php50,000.00) through Cebuana Lheullier and another Fifty
Thousand Pesos(Php50,000.00) to complete the amount was sent
on the following day through RCBC account no.9015605478,

o) That the respondent acknowledged and received the total

amount of One hundred Thousand Pesos(Php100,000.00) and the
respondent told me that he will be arriving on 27 February 2017 at
Santiago to meet me and to make a written agreement about the
transaction and to settle the remaining amount,

p) On 27 February 2017, I personally met the respondent and

we both proceeded to the office of Atty. Lucky M. Damasen in order
to legally formalized our transaction. Memorandum of Agreement [1]
is attached herein and made an integral part hereof;

q) On 28 February 2017, the respondent asked me to withhold

meantime to immediately take over the management of CVKLTC
because of the on-going examination for an applicants to work in
Korea was conducted under the supervision of POEA including the
scheduled examinations in Baguio City on 25-26 March 2017 in
order not to cause confusion and delay in the processing of
necessary documents,

r) The respondent even promised to me that on the 26 th of

March 2017, he will meet with Angie to return the One hundred
Thousand Pesos(Php100,000.00) to enable us to proceed with the
take over of CVKLTC,

________________
[1]
Annex A
 s) But on 26 March 2017, the respondent asked for another
date to take over the CVKLTC. The respondent scheduled the date
right after the announcement of passers in the examination which
was set on 8 April 2017,

t) The respondent likewise admitted during our conversation

that he did not yet met with Angie to return the money because
according to the respondent, the money was diverted and used in
his other investment,

u) The respondent further asked if we are willing to shoulder

amount to be returned to Angie to be able to proceed immediately
with the take over with CVKLTC, with the promised that the
respondent will reimburse to us the said amount on April 8 or 10
2017,

v) I immediately informed my girlfriend regarding the

conversation with the respondent and my girlfriend was convinced
and agreed to part her hard earned money amounting to One
hundred Thousand Pesos(Php100,000.00),

w) On 27 March 2017, I deposited an initial amount Fifty

Thousand Pesos(Php50,000.00) in BDO Account no. 5550106907
but the respondent told me that he will borrow Fifty Thousand
Pesos(Php50,000.00 to his friend named Wendell Valdez Tabin to
complete the amount,

x) On that same date, the respondent told me to send the

remaining Fifty Thousand Pesos(Php50,000.00) on the following day
because the respondent promised to his friend that he will return
immediately the money he borrowed,

y) On 28 March 2017, I deposited the Fifty Thousand

Pesos(Php50,000.00) under BPI account no. 2659084131 in favor of
respondents friend which the respondent affirmatively confirmed
the said amount,

z) Several days had passed, I noticed that Angie was still

occupying the office which is contrary to the promised made by the
respondent,

aa) At that instance, I decided to confront Angie and verify the

status of their agreement with the respondent pertaining to her
rights with the management of CVKLTC,
 bb) To my dismay, I learned that the respondent did not
deposit any amount in favor of Angie and the Fifty Thousand
Pesos(Php50,000.00) that was previously deposited was returned to
the respondent as per his instruction.

cc) On 25 April 2017, the complainant seek the legal

assistance of Atty. Lucky Damasen and a demand letter addressed
to the respondent requiring him to return the amount of Two
Hundred Thousand Pesos(Php200,000.00) [2];

IN WITNESS WHEREOF, I have hereunto set my hand this 25 th

day of May 2017, at Santiago City,Isabela.

VINCENT BACANI PUA

Complainant
Drivers Lic.no.B12-11-001546

SUBSCRIBED AND SWORN before me this 25th day of May

2017, at Santiago City Philippines; Affiant exhibited to me his
identifying evidence as required by the Rules, who signed the said
instrument in my presence. I further certify that I have personally
examined the affiant and I am convinced that the same is his own
free and voluntary act and deed.

_______________________
Prosecutor