Republic of the Philippines

Department of Justice
Office of the City Prosecutor
Batangas City

SENCAR INDUSTRIAL CORPORATION,

represented by ROWENA S. BARREDO,
Complainant,
IS NO._________________
For: Violation of B.P. 22
-versus-

MICHAEL CHING CRUZ,

Respondent.
X---------------------------------X

COMPLAINT-AFFIDAVIT

I, ROWENA S. BARREDO, of legal age, Filipino and a resident

of Ibaan, Batangas, after having been duly sworn to in accordance
with law hereby depose and state:

I am the Credit and Collection Officer and the duly authorized

representative of SENCAR INDUSTRIAL CORPORATION (SENCAR),
a corporation duly organized and existing under Philippine laws, with
office address at Mahabang Parang, Batangas City. Copy of the
Secretary’s Certificate is attached hereto as Annex “A”;

That Respondent MICHAEL CHING CRUZ is of legal age,

owner/proprietor of Visible Trading with residence and business
address at 22 Maximo Viola St., Balingasa, Quezon City and previous
client of herein complainant;

That from the period of June 28, 2015 to August 21, 2015,
Respondent MICHAEL CHING CRUZ, as owner/proprietor of Visible
Trading, transacted with the Complainant SENCAR through its Vice
President and Marketing Manager Mr. Jimmy Tan, wherein the
Respondent MICHAEL CHING CRUZ purchased from SENCAR plastic
(PP) sacks totaling 404,000 pieces;

That as payment for Respondent MICHAEL CHING CRUZ’s

obligation with the Complainant, Respondent drew, made and issued
to the Complainant SENCAR INDUSTRIAL CORPORATION, duly
represented by its Vice President and Marketing Officer Mr. Jimmy
Tan, the following checks:

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 1. BDO Check with Check No. 818925, Account No.
06228020722, and with Account Name of VISIBLE TRADING
in the amount of Two Hundred Fifty Thousand Pesos
(Php250, 000.00) dated June 28, 2015;

2. BDO Check with Check No. 818930, Account No.

06228020722, and with Account Name of VISIBLE TRADING
in the amount of Three Hundred Thirty Two Thousand Pesos
(Php332, 000.00) dated July 10, 2015;

3. BDO Check with Check No. 818926, Account No.

06228020722, and with Account Name of VISIBLE TRADING
in the amount of Two Hundred Fifty Thousand Pesos
(Php250, 000.00) dated July 15, 2015;

4. BDO Check with Check No. 818931, Account No.

06228020722, and with Account Name of VISIBLE TRADING
in the amount of Three Hundred Thirty Two Thousand Pesos
(Php332, 000.00) dated July 25, 2015;

5. BDO Check with Check No. 818933, Account No.

06228020722, and with Account Name of VISIBLE TRADING
in the amount of One Hundred Seven Thousand Nine
Hundred Pesos (Php107, 900.00) dated July 30, 2015;

6. BDO Check with Check No. 818927, Account No.

06228020722, and with Account Name of VISIBLE TRADING
in the amount of One Hundred Twenty Two Thousand Eight
Hundred Pesos (Php122, 800.00) dated July 31, 2015;

7. BDO Check with Check No. 818935, Account No.

06228020722, and with Account Name of VISIBLE TRADING
in the amount of Four Hundred Twenty Three Thousand
Eight Hundred Pesos (Php423, 500.00) dated August 21,
2015.

Copy of the said checks are hereto attached as Annexes “B” to

“H”, respectively and made integral part hereof;

That however, when the Complainant presented the said

checks for payment with the drawee banks, the same were
dishonored and returned to Complainant for the reason either “Non
Suff. Funds” or “Account Closed”;

That Complainant caused the personal service and delivery of

demand letter dated May 4, 2016 to the Respondent MICHAEL

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CHING CRUZ, informing the latter of the fact of dishonor of their
checks and demanding payment of the amount thereof within five (5)
days from receipt of the letter. The said letter was delivered to and
was received by Lhanie Flores respondent’s employee, on May 7,
2016. The photocopy of the demand letter dated May 4, 2016 is
hereto attached as Annex “I” and made an integral part hereof;

That however, despite notice and demand, Respondent

MICHAEL CHING CRUZ failed and refused and still fails and refuses
to pay or make arrangement for full payment of his obligation to the
herein Complainant, including the amount of the subject checks;

That Complainant, because of the dishonor of the said checks,

suffered damages in the amount of ONE MILLION EIGHT HUNDRED
EIGHTEEN THOUSAND TWO HUNDRED PESOS (Php1,818,200.00)
which is the total amount of the SEVEN (7) checks issued to
complainant, excluding the other amounts covered by other checks;

That I am executing this Affidavit to attest to the truth of the

foregoing statements and as well as to charge Respondent MICHAEL
CHING CRUZ for Violation of Batas Pambansa Bilang 22.

IN WITNESS WHEREOF, I have hereunto set my hand this

______________________ in Batangas City.

ROWENA S. BARREDO
Affiant

SUBSCRIBED AND SWORN to before me this ________________at

Batangas City.

Administering Officer

CERTIFICATION

I HEREBY CERTIFY that I have personally examined the affiant

and that I am convinced that she voluntarily executed and
understood the contents of her affidavit.

Administering Officer