Republic of the Philippines

Region 10
Municipal Trial Court
Iligan City
Branch __

Ray Fortunado
Complainant,

-versus- Civil Case No. _____

For: Violation of BP Blg. 22
Juan Dela Cruz
Respondent.
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COUNTER-AFFIDAVIT

I, Juan Dela Cruz, of legal age, married, and with residence or postal address at
4th East, Purok West, Tubod, Iligan City after having been duly sworn to in accordance
with law, hereby depose and say that:

I am the respondent in the above-entitled case. The complaint is anchored

mainly on perjurious statements and being filed for harassment purposes only. For this
reason, the complaint filed by the complainant should be dismissed outright. And this is
to rebut and contradict Ray Fortunado’s lies. I respectfully avers that:

1. I admit paragraphs 1, 2 and 3, but portion of the paragraphs lack adequate

knowledge to form as to the truth thereof.
2. I admit paragraph 4, but the demand for payment was sent to me through
email and the complainant demanded the payment involving force and
threats. After receiving also the notice of dishonor made by the respondent,
we had agreed that I will issue another check for the payment of the loan for I
 was not able to fund the said check due to series of losses suffered by the
business. Moreover, I offered an offering of one hundred thousand pesos
(P100,000.00) as a fractional payment for the loan that was received last
February 10, 2019 but the complainant denied it. A copy of the demand for
payment sent through email and the new agreement to issue another check
are attached as “Annex A” and “Annex B”, respectively.
3. I reject the contention of the complainant that I ignored the the notice of
dishonor and demand for payment. And that i did not employed any deceit in
the issuance of a dishonored check.
4. We, the complainant and the respondent, made a new contract that i will pay
the loan on or before June 10, 2019. An original copy of the contract is
attached as ‘Annex C”.

I WITNESS WHEREOF, I hereby affix my signature this 15 th day of March, in the

City of Iligan, Philippines.
Juan Dela Cruz
Affiant

SUBSCRIBED AND SWORN TO before me this 15th day of March, in the City of
Iligan, Philippines and I further certify that I ahve personally examines that he voluntarily
executed the foregoing Counter Affidavit and understood all the contents hereof and
that they are true and correct as to his own personal knowledge.

Anna Marie Sanchez

Attorney
Roll No. ____
IBP No. ____
PTR No. _______; Iligan City
MCLE Compliance III No. ____
Issued on _______