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That I, Michael Jordan, of legal age, married, Filipino and a resident of c/o
South Bank, Kauswagan Branch, Cagayan de Oro City, after having been duly
sworn to according to law hereby depose and say: 4. BODY (Allegations)

1. That I am the Loan Manager of South Bank, Kauswagan Branch, Cagayan de

Oro City. I am executing this affidavit in behalf of South Bank, being the
complainant herein.

2. In behalf of the said Rural Bank, I am filing a formal complaint for Estafa
thru Falsification of Public Document and /or thru Forgery against
respondent Lebron James [hereinafter Respondent], a resident of
Vamenta, Carmen, Cagayan de Oro City .

3. On October 31, 2007, Respondent using the name of, and misrepresenting
herself to be Doa Aiqa Macarambon-Bacsarpa, submitted a loan
application, purportedly signed by the Spouses, by forging their signatures
with South Bank, Kauswagan Branch, Cagayan de Oro City amounting to PhP

4. As security for the payment of the said loan, Respondent submitted as

collateral thereof a parcel of land described in TCT No. T-178439 1 and
executed a Real Estate Mortgage over the said land in favor of South Bank.

5. On December 6, 2007, the loan application amounting to Philippine Pesos:

Five Million (PHP 5,000,000.00) was approved by South Bank and the
proceeds thereof were delivered to the Respondent, receipt of which is
evidenced by a managers check issued by the bank and withdrawn by the
Respondent. Photocopy of the said check is hereto attached as Annex C

6. On January 6, 2007, South Bank found out that respondent falsified and/or
forged the above mentioned documents. It also found out that Respondent
misrepresented herself to be Doa Aiqa Macarambon-Bacsarpa when in
truth and in fact the former, as found by the bank, is Apipa G. Guro.
Respondents 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. Respondents unlawful acts were discovered by the bank when the latter
tried to collect from the Spouses Bacsarpa 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 South Bank;

8. The unlawful acts by Respondent caused damage and prejudice to South

Bank in the amount of PhP 5,000,000.00, the amount released to
respondent as proceeds of the loan, including interest of twelve percent
(12%) per annum;

9. South Bank spent PhP 30,000.00 for attorneys fees for filing the complaint

10.That I am executing this affidavit for and behalf of the South Bank,
Kauswagan, Cagayan de Oro City, being the Loan Manager thereof, to file a
formal complaint of Estafa through Falsification of Public Documents and/or
through Forgery against Apipa Guro.

Affiant further sayeth naught.

IN WITNESS WHEREOF, I have hereunto affixed my signature for and in

behalf of the complainant South Bank Kauswagan, Cagayan de Oro City this 8th
day of December 2009, at Cagayan de Oro City. 5. ATTESTATION CLAUSE

6. SUBSCRIBER under Sec.

3 of Rule 110
Michael Jordan
(Subscriber) Affiant

SUBSCRIBED and SWORN to before me this 8th day of December, 2009, at

Cagayan de Oro City. I hereby certify that I have personally examined the above-
named affiant and that I am satisfied that the foregoing statements were given by
him voluntarily and of his own free will.

Stephen Curry
Associate Prosecution Attorney II
Sec. 3, Par. (a) of Rule 112