Republic of the Philippines }

Province of Davao del Norte }s.s.

City of Panabo }

COMPLAINT-AFFIDAVIT

I, RONNIE P. CUCHARO, Filipino, of legal age, with office address at Km 29 National

Highway, Panabo City, Davao del Norte, after having been duly sworn in accordance with law,
do hereby depose and state that:

1. I am the Vice President for Sales and Operation of INNOVAPLAS PACKAGING

CORPORATION, said company being a domestic corporation engaged in the business
of producing and exporting plastic goods with principal office at Km 29 National
Highway, Panabo City, Davao del Norte, hereinafter referred to as “IPC" for brevity;

2. Along with my duties and responsibilities as such, is to represent the company in the
cases it files before any court/tribunal/judicial agency in order to protect its interests, as
manifested in the herein attached Board Resolution and herein marked as Annex "A";

3. As mentioned above, IPC is engaged in the business of producing and exporting plastic
products, and among its clients is an establishment known as “GTC MARKETING"
owned and managed by MARIA THERESA MARTINES CASINO;

4. Said business establishment has its known office address at West Kiwabe, Kiwabe,
Bukidnon as represented by its Owner/Proprietor MARIA THERESA M. CASINO
with the same residence address at the aforementioned business address, who are
authorized to accept summons and legal processes in all legal proceedings & all notices
affecting the aforementioned establishment at its aforementioned business address;

5. On various dates commencing from July 2016 up to August 2016, MS. MARIA
THERESA M. CASINO, doing business under the name of GTC MARKETING,
engaged the services of IPC in furtherance of their business activity. In the course
thereof, GTC MARKETING has incurred several unpaid obligations to IPC;

6. Commencing from July 2016, GTC MARKETING has failed to pay their accounts
regularly to IPC which in turn made them incurred a total obligation of ONE HUNDRED
AND TWELVE THOUSAND FIVE HUNDRED EIGHT AND TEN CENTAVOS (Php
112,508.10) as reflected in the herein attached Statement of Demand Letter made by its
Credit and Collection Officer, Mr. Charles L. Cornel dated August 17, 2016, and marked
as Annex “B”.

7. From that date onwards, IPC found it hard to collect for payments from GTC
MARKETING in spite of several demand letters which were sent to and received by
them;

8. Proper notifications and demand were made and sent to Ms. Maria Theresa M. Casino,
the latter being the signatory of the check, so that they or she could replace them with
CASH and/or settle said accountability with the reason of the return thereof. Copy of the
latest demand letter is hereto attached and marked as Annex “E” hereof;
 9. In spite of the successive demand letter sent by our counsel, MS. MARIA THERESA M.
CASINO and/or GTC MARKETING, failed and refused, and continue to fail and refuse
to redeem in cash the face amount of the unfunded returned check. Filing of this case was
even suspended for almost several times already just to give them the ample time and
opportunity to settle their obligations in full, but the same served futile;
10. I am executing this affidavit to attest to the truth of the foregoing facts and for the
purpose of charging MS. MARIA THERESA M. CASINO as Owner/Proprietor of the
business GTC MARKETING for violation of the provisions of BATAS PAMBANSA
BLG. 22.

AFFIANT FURTHER SAYETH NAUGHT.

Panabo City, Davao del Norte, Philippines, October 2, 2017.

INNOVAPLUS PACKAGING CORP.

Complainant

By
RONNIE P. CUCHARO
Affiant

SUBSCRIBED AND SWORN to before me, this ____ day of _______________,

Panabo City, Davao del Norte, Philippines, affiant exhibiting to me his Drivers License
No_______________

CITY PROSECUTOR

I hereby certify that I have personally examined the affiant and that I am fully satisfied
that she voluntarily executed and understood her sworn statement.

CITY PROSECUTOR