REPUBLIC OF THE PHILIPPINES

OFFICE OF THE PROVINCIAL PROSECUTOR

3RD Regional Trial Court Building, Tarlac City

JESUSA IGNACIO,
Complainant,

versus

LIEZEL D. TABONG,
Respondent.

x-------------------------------x .

COMPLAINT-AFFIDAVIT

THE UNDERSIGNED COMPLAINANT respectfully alleges,

I, JESUSA IGNACIO, of legal age, married, Filipino, and a resident of Barangay Abagon
Gerona, Tarlac, after being sworn in accordance with law, hereby depose and state that:

I. On June 26, 2019 a certain LIEZEL D. TABONG, resident of Barangay Apsayan,

Gerona, Tarlac, anxiously approached me for monetary assistance for she claimed
to be very urgent that she need to immediately address;

II. With her ardent appeal and sweet words and as a friend whom for some time an Commented [A1]:
undue trust and confidence was develop within me of her posing kindness and
sincerity the said person was able to persuade me of her claim of the nature of the
urgency of help that she need;

III. On the abovementioned date, I lend her some amount of money, an instant cash of
Five Thousand Pesos (PhP5,000.00); and the next day June 27, 2019, she again
approached me for another Five Thousand Pesos (PhP,5,000.00) and consequently,
I gave the said amount;

IV. Ms. Tabong made a promise to me that she will give me back the whole amount of
Ten Thousand Pesos (PhP10,000.00) in just a couple of days after the 27th of July,
2019;
 V. On the same date June 27, just upon giving her second plea, she asked me if what
help she can humbly reciprocate to my kindness and how little as it may she will
gladly do it for me then;

VI. So then I ask her if she may have some extra time to go to the Tarlac Electric
Cooperative Office to pay for my electric bill and I gave her Five Hundred Paseos
(PhP500.00) for the bill;

VII. After the date(s) that Ms. Tabong, promised me give back the aforementioned
amount of PhP10,000.00, I made a frequent call and text messages to ask her to
give back the said amount of money and while I am making hard time to locate her,
I discovered that even the PhP500 was not paid to TARELCO II;

VIII. I made efforts to locate her (Ms. Tabong) through phone call and text messages she
continued not to respond and ignored my calls;

IX. With the abovementioned circumstances, I went to the Office of the Barangay
Apsayan and filed my complaint (copy of the complaint is hereto attached and
marked as Annex “A”) and for the Barangay Justice call her attention to the matter;

X. She must be a bit anxious of the complaint I filed and to somehow appease me she
ask her cousin and I was notified from a text message that Tabong is giving me her
Automated Teller Machine Card (ATM CARD) which she claim to have some PhP
23,000.00 that I will withdraw the whole amount and give her the rest from the
PhP10,000.00 which I am asking her to give back, unfortunately the said ATM
Card has no fund on deposit;

XI. After some four (4) summons that she signed for her information she continued to
ignore and never attended the hearing(s), the Punong Barangay then issued a
certificate to file action and that the matter can now be elevated to higher hall of
justice.

Wherefore, with the aforementioned circumstances and in the name of Justice and Fairness
the undersigned humbly pray to the Honorable Prosecutor to charge LIEZEL D. TABONG for
violation of Article 308 and Article 309 of the Revised Penal Code of the Philippines, other relief
for the aforementioned offense is also prayed for.

Affiant sayeth none.