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REPUBLIC OF THE PHILIPPINES}

DONE: IN THE CITY OF BAGUIO } S.S.


X =========================== X

COMPLAINT-AFFIDAVIT

That I, JOANNA VERNAL, of legal age, single, Filipino and a resident of 74 Rimando
Rd.,Aurora Hill, Baguio City, after having been duly sworn to according to law hereby depose
and say:

1. That I am the Loan Manager of Summit Bank, Magsaysay Branch-Baguio City. I am


executing this affidavit in behalf of Summit Bank, being the complainant therein;

2. In behalf of the said Bank, I am filing a formal complaint for Estafa thru Falsification of
Public Document and /or thru Forgery against respondent ESTA FADORA [hereinafter
“Respondent”], a resident of 89 Guisad, Baguio City;

3. On October 7, 2011, Respondent using the name of, and misrepresenting herself to be
Doña Añiqa Macarombon-Bacsampa, submitted a loan application, purportedly signed by
the Spouses, by forging their signatures with Summit Bank, Magsaysay Branch-Baguio
City, amounting to Php5,000,000.00;

4. As security for the payment of the said loan, Respondent submitted as collateral thereof a
parcel of land described in TCT No. T-05960, and executed a Real Estate Mortgage over
the said land in favor of Summit Bank.

5. On December 6, 2011, the loan application amounting to Five Million Pesos


(Php5,000,000.00) was approved by Summit Bank and the proceeds thereof were
delivered to the Respondent, receipt of which is evidenced by a manager’s check issued
by the bank and withdrawn by the Respondent, a copy of the said check is hereto attached
as Annex A hereof;

6. On January 6, 2012, Summit Bank found out that respondent falsified and/ or forged the
above mentioned documents, it also found out that respondent misrepresented herself to
be Doña Añiqa Macarombon-Bacsampa when in truth and in fact the former, as found by
the bank as Apipa G. Guro. Respondent’s 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. Respondent’s unlawful acts were discovered by the bank when the latter tried to collect
from the Spouses Bacsampa who refused to pay on the ground that they did not apply for
a loan, much less mortgage the land covered by subject land title in favor of Summit
Bank;

8. The unlawful acts by Respondent caused damage and prejudice to Summit Bank in the
amount of Php5,000,000.00, the amount released to respondent as proceeds of the loan,
including interest of twelve percent (12%) per annum;

9. Summit Bank spent Php30,000.00 for attorney’s fees for filing the complaint affidavit

10. That I am executing this affidavit for and behalf of the Summit Bank Magsaysay Branch-
Baguio City; being the Loan Manager thereof, to file a formal complaint of Estafa
through Falsification of Public Document and / or through Forgery against Agapipa G.
Guro
IN WITNESS WHEREOF, I have hereunto affixed my signature for and in behalf of
the complainant Summit Bank Magsaysagy Banch- Baguio City this 1 st day of February 2014, at
Baguio City, Philippines.

JONNA VERNAL
Affiant

SUBSCRIBED AND SWORN to before me in the City of Baguio this 1st day of February
2014. I hereby certify that I have personally examined the above named affiant and that I am the
foregoing statements were given by her voluntarily and of his own free will.

_______________________
Investigating Prosecutor

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