Garcia Law Office “ANNEX B”

Pedro Castro 4th April 2020

#24 Camel Street, Barangay Santa Rita,
Guiguinto, Bulacan

Demand Letter with Notice

of Dishonor of Checks

Dear Mr. Castro,

We are writing for and behalf of my client, JUAN SANTOS of Guiguinto, Bulacan.

Upon communication with our client, it came to our knowledge that you have an outstanding
demandable obligation with our client, the total amount of which is SIXTY THOUSAND (P 60,000.00)
PESOS.

That in consideration of the sold amount you owe to our client, you have issued a twelve (12)
Post-dated Metrobank Checks with a face value of SIXTY THOUSAND (P 60,000.00) PESOS and bearing
number(s) 0000000001, 0000000002, 0000000003, 0000000004, 0000000005, 0000000006,
0000000007, 0000000008, 0000000009, 0000000010, 0000000011, and 0000000012 and under the
account name Pedro Castro. Upon presentment however, the said check was dishonored for the reason
“account closed.”

By reason of the non-payment of your current obligation, FINAL DEMAND and NOTICE OF
DISHONOR is hereby made to you, by our client JUAN SANTOS, through this letter, for the immediate
payment of your debt of SIXTY THOUSAND (P 60,000.00) PESOS.

We are giving you TEN (10) DAYS from your receipt of this Demand Letter, within which to pay
the remaining balance of your obligation, otherwise we shall be constrained to exhaust all legal remedies
available.

Your failure to pay the said obligation within the sad TEN (10) day period, shall compel us to take
all necessary legal actions/s to protect the interest of our client, which includes but not limited to, the
filing of CRIMINAL CASE possibly for violation of BP 22 and/or estafa, and/or filing of CIVIL CASE in the
proper courts or tribunals. Please give this matter your preferential attention to save yourself from the
embarrassment and inconvenience of having to face civil and criminal charges in court.

You may contact JUAN SANTOS, his representative or the undersigned counsel through this e-mail
address cjegarcia28@yahoo.com or call through +639054520228 to settle your obligation or coordinate
any concerns.

Very truly yours,

ATTY. CHRISTIAN JOSEPH E. GARCIA

For Juan Santos
GARCIA LAW OFFICES
“ANNEX A”
 “ANNEX C”

MALOLOS BULACAN

002 Guiguinto, Bulacan

PEDRO CASTRO

April 8
20
 REPUBLIC OF THE PHILIPPINES
OFFICE OF THE CITY PROSECUTOR
CITY OF MALOLOS, BULACAN

JUAN SANTOS
Complainant,
Criminal Case No.: 2020-10

For: Violation of B.P. Blg. 22

- Versus -

PEDRO CASTRO
Respondent,
x-------------------------------------x

COMPLAINT-AFFIDAVIT

I, JUAN SANTOS, Filipino, of legal age, single, and a resident of #321

Burgos Street, Santa Rita, Guiguinto, Bulacan, Philippines, after being
sworn to in accordance with law, depose and state:

1. That I know the person of PEDRO CASTRO, who is a resident

of #24 Camel Street, Barangay Santa Rita,Guiguinto, Bulacan,
Philippines;

2. That sometime in December 20, 2018, at #321 Burgos Street,

Santa Rita, Guiguinto, Bulacan, Philippines, the said PEDRO
CASTRO issued in my favor a Metrobank Check No.
0000000001 in the amount of FIVE THOUSAND (P 5,000.00) as
supposed payment for the contract of lease entered by the
parties;

3. That sometime in December 20, 2018, at #321 Burgos Street,

Santa Rita, Guiguinto, Bulacan, Philippines, the said PEDRO
CASTRO issued in my favor a Metrobank Check No.
0000000002 in the amount of FIVE THOUSAND (P 5,000.00) as
supposed payment for the contract of lease entered by the
parties;
4. That sometime in December 20, 2018, at #321 Burgos Street,
Santa Rita, Guiguinto, Bulacan, Philippines, the said PEDRO
CASTRO issued in my favor a Metrobank Check No.
0000000003 in the amount of FIVE THOUSAND (P 5,000.00) as
supposed payment for the contract of lease entered by the
parties;

5. That sometime in December 20, 2018, at #321 Burgos Street,

Santa Rita, Guiguinto, Bulacan, Philippines, the said PEDRO
CASTRO issued in my favor a Metrobank Check No.
0000000004 in the amount of FIVE THOUSAND (P 5,000.00) as
supposed payment for the contract of lease entered by the
parties;

6. That sometime in December 20, 2018, at #321 Burgos Street,

Santa Rita, Guiguinto, Bulacan, Philippines, the said PEDRO
CASTRO issued in my favor a Metrobank Check No.
0000000005 in the amount of FIVE THOUSAND (P 5,000.00) as
supposed payment for the contract of lease entered by the
parties;

7. That sometime in December 20, 2018, at #321 Burgos Street,

Santa Rita, Guiguinto, Bulacan, Philippines, the said PEDRO
CASTRO issued in my favor a Metrobank Check No.
0000000006 in the amount of FIVE THOUSAND (P 5,000.00) as
supposed payment for the contract of lease entered by the
parties;

8. That sometime in December 20, 2018, at #321 Burgos Street,

Santa Rita, Guiguinto, Bulacan, Philippines, the said PEDRO
CASTRO issued in my favor a Metrobank Check No.
0000000007 in the amount of FIVE THOUSAND (P 5,000.00) as
supposed payment for the contract of lease entered by the
parties;

9. That sometime in December 20, 2018, at #321 Burgos Street,

Santa Rita, Guiguinto, Bulacan, Philippines, the said PEDRO
CASTRO issued in my favor a Metrobank Check No.
0000000008 in the amount of FIVE THOUSAND (P 5,000.00) as
supposed payment for the contract of lease entered by the
parties;

10. That sometime in December 20, 2018, at #321 Burgos

Street, Santa Rita, Guiguinto, Bulacan, Philippines, the said
 PEDRO CASTRO issued in my favor a Metrobank Check No.
0000000009 in the amount of FIVE THOUSAND (P 5,000.00) as
supposed payment for the contract of lease entered by the
parties;

11. That sometime in December 20, 2018, at #321 Burgos

Street, Santa Rita, Guiguinto, Bulacan, Philippines, the said
PEDRO CASTRO issued in my favor a Metrobank Check No.
0000000010 in the amount of FIVE THOUSAND (P 5,000.00) as
supposed payment for the contract of lease entered by the
parties;

12. That sometime in December 20, 2018, at #321 Burgos

Street, Santa Rita, Guiguinto, Bulacan, Philippines, the said
PEDRO CASTRO issued in my favor a Metrobank Check No.
0000000011 in the amount of FIVE THOUSAND (P 5,000.00) as
supposed payment for the contract of lease entered by the
parties;

13. That sometime in December 20, 2018, at #321 Burgos

Street, Santa Rita, Guiguinto, Bulacan, Philippines, the said
PEDRO CASTRO issued in my favor a Metrobank Check No.
0000000012 in the amount of FIVE THOUSAND (P 5,000.00) as
supposed payment for the contract of lease entered by the
parties;

14. That the said checks are drawn against the account of the
said PEDRO CASTRO at METROBANK with Account No. 01-
02934183;

15. That at the time the said PEDRO CASTRO issued the
delivered the said checks to me, he made the assurance and
representation that the said check is a good check and would be
covered by sufficient funds when presented for payment;

16. However, when the above-mentioned checks were

deposited, the same were 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
checks are hereto attached as Annex "A";

17. As such, I notified said PEDRO CASTRO of the dishonor

and return of the said check and demanded from him that he
make good the said check within Ten (10) days from receipt
 thereof. A true and faithful machine reproduction of my demand
letter to him is hereto attached as Annex "B"

18. When said PEDRO CASTRO 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 April 4, 2020, which was received by PEDRO CASTRO
on April 6, 2020. Attached herein as “Annex C”

19. As of date however, PEDRO CASTRO has unjustifiably

ignored all these demands to pay the said account and/or to
redeem the said returned check.

20. I am therefore executing this Complaint-Affidavit in support

of the charges for Violation of Batas Pambansa Bilang 22 against
PEDRO CASTRO, who may be served with subpoena and other
processes of this Honorable Office at his last known address at
of #24 Camel Street, Barangay Santa Rita, Guiguinto, Bulacan,
Philippines;
IN WITNESS WHEREOF, I have hereunto set my hand this 17th day
of April at Malolos, Bulacan, Philippines.

JUAN SANTOS
Plaintiff

SUBSCRIBED AND SWORN to before me this 17th day of April 2020

at Malolos Bulacan. I hereby certify that I have examined the Affiant
and that I am fully satisfied that he has voluntarily executed and
understood the contents of his Complaint-Affidavit.

Law Office of Atty. Christian Joseph Garcia

Notary Public
Serial No. 3567
Expiry date December 2022
Notarial Commission
PTR No. 22332
Attorneys Roll No. 70202
IBP membership no. 509
MCLE Compliance: 1022/ December 2021
Mater Dei Building
Poblacion, Malolos, Bulacan
Doc…5
Page….1
Book no. 1
Series of 2020