REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT

Dalaguete, Cebu

PEOPLE OF THE PHILIPPINES,

Plaintiff, CRIM. CASE NO. _____________
FOR: VIOLATION OF B.P. BLG. 22
-versus- (2 Counts)

EVELYN AHMAD,
Accused.
X----------------------/

COMPLAINT

The undersigned Chief of Police of Dalaguete Police Station, Dalaguete,

Cebu, under oath accuses EVELYN AHMAD, Filipino citizen, of legal age,
married and a resident of 1815 Ave Garments, CYL Building, Albano St.,
Subangdaku, Mandaue City, Philippines, for two (2) counts of the offense in
Violation of Batas Pambansa Bilang 22 committed as follows:

That on or about May 16, 2008 and June 21, 2008 at Poblacion,
Dalaguete, Cebu, Philippines and within the jurisdiction of this Honorable Court,
the herein accused EVELYN AHMAD, with deliberate criminal intent, did then and
there willfully, unlawfully and feloniously make, draw and issue the following
checks, to wit:

Check No. Drawee Branch Date Amount

Bank

1. MDE A0001570854 China Bank Cebu- 05-16-08 Php100,000.00

Mandaue
Br.

2. MDE A0001570864 China Bank Cebu- 06-21-08 Php100,000.00

Mandaue
Br.

in the total sum of TWO HUNDRED THOUSAND PESOS (Php200,000.00)

payable to the order of UPLAND RURAL BANK OF DALAGUETE (CEBU), INC.,
a banking institution duly established and doing business in the Municipality of
Dalaguete, Cebu, Philippines, well knowing at the time she issued said checks
that she had no sufficient funds with the drawee bank to cover the total amount of
Php200,000.00, and without informing said facts to the payee of the checks,
presented the same to UPLAND RURAL BANK OF DALAGUETE (CEBU), INC.
to be cash for which the accused personally received the total amount of
Php200,000.00 in cash; that upon presentation of said checks with the drawee
bank for payment after its due dates the same were dishonored, rejected and
refused payment for the reason that said checks were drawn by the accused
against a “CLOSED ACCOUNT” and despite repeated demands to the accused
to make good said checks or redeem it with cash accused failed and refused to
the damage and prejudice of Upland Rural Bank of Dalaguete (Cebu), Inc. in the
total amount of Php200,000.00.

CONTRARY TO LAW.
complaint
page-two

Dalaguete, Cebu, Philippines. December 24, 2008.

P/INSP. REYMAN GALERA TOLENTIN

Chief of Police
PNP-Dalaguete Police Station

Witnesses:

1. Mamerto Luis Manguerra

2. Cipriana H. Montenegro
3. And others

SUBSCRIBED AND SWORN to before me on this _____ day of

_______________________, at Dalaguete, Cebu, Philippines.

HON. VIDAL A. GELLA

Acting Presiding Judge
MTC, Dalaguete, Cebu

RECEIVED AND FILED on this ____ day of

________________________, at the Office of the Clerk of Court of MTC-
Dalaguete, Cebu, Philippines.

CYNTHIA B. CARTILLA
Clerk of Court
MTC-Dalaguete, Cebu

RECOMMENDED BAIL BOND IS FIXED AT: __________________