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I, JUDEE ANN CASTILLO, Filipino, of legal age, single, and a resident of Block 8 Lot 20, Santiago Villas, Catalunan Grande, Davao City, Philippines, after being sworn to in accordance with law, depose and state:
That I know the person of NANCY MONROID, who is a resident of 23 Opal St., Phase 4 Ecoland Subdivision, Davao City, Philippines;
That sometime in the morning of July 1, 2009, the said NANCY MONROID, at 23 Opal St., Phase 4 Ecoland Subdivision, Davao City, Philippines issued in my favor a Philippine National Bank Check No. 2346789 in the amount of P210,000 as supposed payment for the loan accommodation of P200,000, which I have extended to her;
That the said check is drawn against the account of the said NANCY MONROID at Philippine National Bank with Account No. 3985129559;
That at the time the said NANCY MONROID issued the delivered the said check to me, she made the assurance and representation that the said check is a good check and would be covered by sufficient funds when presented for payment;
However, when the above-mentioned check was deposited, the same was dishonored and returned by the bank on the ground that the same was drawn against a "CLOSED ACCOUNT." A true and faithful machine reproduction of the said check is hereto attached as Annex "A";
As such, I immediately notified said NANCY MONROID of the dishonor and return of the said check and demanded from her that she make good the said check within fifteen (15) days from receipt thereof. A true and faithful machine reproduction of my demand letter to her is hereto attached as Annex "B";
When said NANCY MONROID failed to heed my demands, I endorsed the said check to my legal counsel who immediately sent a formal demand letter through registered mail with return card on September 23, 2009, which was received by the said NANCY MONROID on September 22, 2009. As of date however, NANCY MONROID has unjustifiably ignored all these demands to pay the said account and/or to redeem the said returned check. A true and faithful machine reproduction of my demand letter to her is hereto attached as Annex "C";
I am therefore executing this Complaint-Affidavit in support of the charges for Violation of Batas Pambansa Bilang 22 against the said NANCY MONROID, who may be served with subpoena and other processes of this Honorable Office at her last known address at 23 Opal St., Phase 4 Ecoland Subdivision, Davao City, Philippines;
IN WITNESS WHEREOF, I have hereunto set my hand this 9th of October, 2009 at Davao City, Philippines.
JUDEE ANN CASTILLO
SUBSCRIBED AND SWORN to before me this 9th of October, 2009 at Davao City, Philippines. I hereby certify that I have examined the Affiant and that I am fully satisfied that she has voluntarily executed and understood the contents of her Complaint-Affidavit.
ATTY. JOAHNNA EVE S. TEJERO ROLL NO. 89101 IBP NO. 533790/01-02-07 PTR NO. 849760/01-10-09/Davao City