REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
BAGUIO CITY

Mr. NAGOYA
Complainant
Crim. Case No.

FOR: Violation of B.P. Blg. 22.

-versus-

Mr. NALINLANG
Respondent
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COMPLAINT-AFFIDAVIT

THE UNDERSIGNED COMPLAINANT respectfully alleges:

I, MR. NAGOYA, of legal age, Filipino, single, and a resident of Baguio City,
Philippines, after having been duly sworn to in accordance with law, hereby accuses:

MR. NALINLANG, a staff of Mysterio Investment Firm, with postal address at

Baguio City where summons and notices may be served for violation of BP 22
committed as follows:

1. Sometime in March 2015, I decided to invest my money with MR. ESTAFADOR,

owner of Mysterio Investment Firm and the latter’s staff MR. NALINLANG, a total
amount of P 1,000,000, evidenced with a receipt marked as Annex “A”;

2. After a few months, I demanded the return of my total investment because I had
to fund his ukay-ukay business;

3. Consequently, I received amounts in the form of checks issued by Mr. Estafador;

4. For reasons unknown, Mr. Estafador instructed me to return the checks which
were later on the checks with Mr. Estafador’s signatures were replaced by
checks signed by his staff Mr. Nalinlang. Photocopy of the said checks are hereto
attached and marked as Annex “B”. The checks are BPI checks with the
following dates and amounts:

BPI check no. 08093 July 15, 2016 P 250,000

BPI Check no. 08094 August 15, 2016 P 250,000
BPI Check no. 08095 September 15, 2016 P 250,000
BPI Check no. 08096 October 15, 2016 P 250,000

5. Later on, I deposited the checks with my bank BDO SM branch ten days after
the date indicated in each check but the checks were all successively dishonored
when sent to BPI and returned to BDO with the following stamp “CLOSED
ACCOUNT” evidenced here as Annex “C”;
 6. However the I was only fed up with the promises, through a notice of dishonour
with demand dated April 10, 2016, I informed Mr. Estafador and Mr. Nalinlang of
the dishonor of the checks and demanded from them to make good the said
checks within FIVE banking days from receipt of the notice. Copy of the said
notice is hereto attached and marked as Annex “D”;

7. In spite of the successive demand letter sent by my counsel, Mr. Estafador and
Mr. Nalinlang failed and refused, and continue to fail and refuse to redeem in
cash the face amount of the unfunded returned check. At present Mr. Estafador
already left for China and could not be found.

8. I am executing this affidavit to attest to the truth of the foregoing facts and for the
purpose of charging MR. NALINLANG for violation of the provisions of BATAS
PAMBANSA BLG. 22.

IN WITNESS WHEREOF, I have hereunto affixed my signature this April 13,

2019 in the City of Baguio, Philippines.

MR. NAGOYA
Affiant

SUBSCRIBED AND SWORN TO before me this April 13, 2019 at Baguio City,
Philippines. I HEREBY CERTIFY that I have personally examined the affiant and that I
am fully satisfied that she voluntarily executed and understood the same.

Notary Public