REPUBLIC OF THE PHILIPPINES

Province of Bulacan )s.s

Municipality of Guiguinto

x-------------------------------x

COMPLAINT-AFFIDAVIT

I, JUAN SANTOS, Filipino, of legal age, married , and a

resident of , Lot 07, Blk 58 Ramona Subdivision Sta Cruz, Guiguinto,
Bulacan, Philippines, after being sworn to in accordance with law,
depose and state:

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

resident of Lot 09, Blk 25 Ramona Subdivision Sta Cruz,
Guiguinto, Bulacan, Philippines;

2. That sometime in the morning of December 2018, Respondent

issued 12 post dated checks;

3. That the said checks are drawn against the account of the said
Respondent Pedro Castro at MetroBank Guiguinto with Account
No. 01-02934183;

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

5. However, when the above-mentioned check was deposited, the

same was 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 check is hereto
attached as Annex "A-1 to A-12;

6. As such, I immediately notified Respondent through a demand

letter sent through registered mail with return card on March 21,
2020, which was received by the said Respondent on March 25,
2020.said Respondent of the dishonor and return of the said
check and demanded from (him/her) that he make good the said
check within five (5) days from receipt thereof. A true and
faithful machine reproduction of my demand letter to him is
 hereto attached as Annex "B" and the faithful machime
reproduction of return card attached as Annex “C”;

7. As of date however, Respondent has unjustifiably ignored all

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

8. I am therefore executing this Complaint-Affidavit in support of

the charges for Violation of Batas Pambansa Bilang 22 against
the said Pedro Castro, who may be served with subpoena and
other processes of this Honorable Office at his last known
address at Lot 09, Blk 25 Ramona Subdivision Sta Cruz,
Guiguinto, Bulacan, Philippines, Philippines;

IN WITNESS WHEREOF, I have hereunto set my hand this 27th day of

March, 2020 at Guiguinto, Province of Bulacan, Philippines.

JUAN SANTOS
signed
Complainant

SUBSCRIBED AND SWORN to before me this 27th day of March 2020

at Guiguinto, Province of Bulacan, Philippines. 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.

Santos-Ablen Law Offive

Room 302, Villafuerte Bldg
Venus St, Camdaba
Malolos, Bulacan

By:

Signed.
Atty. Michaela De Guzman
Roll no. 157
PTR No. 1236
IBP No. 1572
MCLE Compliance V-426378-98
 VERIFICATION and

CERTIFICATION AGAINST FORUM SHOPPING

I, JUAN SANTOS, after having been duly sworn to in

accordance with law, hereby depose and say that:

1. I have read and understood all the allegations of facts

therein, which are true and correct of my own personal
knowledge and based on authentic
documents/records.

2. Plaintiff has not commenced any other action or

proceeding involving the same issues in the Supreme
Court, the Court of Appeals, or any other tribunal or
agency. To the best of my knowledge, no such action
or proceeding is pending in the Supreme Court, Court
of Appeals, or any other tribunal or agency. If there is
any such action or proceeding which is either pending
or may have been terminated, I undertake to inform
this Honorable Court of the status of the same within
five (5) days from knowledge of such fact.
 IN WITNESS WHEREOF, I have hereunto affixed my
signature this 27th day of March 2020, in the City of Malolos,
Bulacan.

JUAN SANTOS
signed
Affiant

SUBSCRIBED AND SWORN to before me, this 27th day of

March 2020, in the City of Malolos, Bulacan, Philippines,
affiants exhibiting to me their SSS identification card bearing
their picture and signature known to me to be the same
person who verified and certified the foregoing complaint and
acknowledged to me that the same is his free act and
voluntary deed.

Doc. No. 09

Book No. 07

Page No.55

Series of 2020.
 Annex “A -1”

Annex “A -2”

Annex “A -3”

Annex “A -4”
Annex “A -5”

Annex “A -6”

Annex “A -7”

Annex “A -8”
 Annex “A -9”

Annex “A -10”

Annex “A -11”

Annex “A -12”
 Annex “B”

March 21, 2020

Pedro Castro
Lot 09, Blk 25 Ramona Subdivision
Sta Cruz, Guiguinto, Bulacan

Re: Notice of Dishonor and Demand for Payment

Dear Mr Castro:

This is to advise you that the following checks has been dishonored for
the reason “account closed”:

1. Metrobank Check No. 000000001 for P 5,000 due and payable on

January 1, 2019

2. Metrobank Check No. 000000002 for P 5,000 due and payable on

February 1, 2019

3. Metrobank Check No. 000000003 for P 5,000 due and payable on

March 1, 2019

4. Metrobank Check No. 000000004 for P 5,000 due and payable on

April 1, 2019

5. Metrobank Check No. 000000005 for P 5,000 due and payable on

May 1, 2019

6. Metrobank Check No. 000000006 for P 5,000 due and payable on

June 1, 2019

7. Metrobank Check No. 000000007 for P 5,000 due and payable on

July 1, 2019

8. Metrobank Check No. 000000008 for P 5,000 due and payable on

August 1, 2019

9. Metrobank Check No. 000000009 for P 5,000 due and payable on

September 1, 2019

10. Metrobank Check No. 0000000010 for P 5,000 due and payable
on October 1, 2019

11. Metrobank Check No. 0000000011 for P 5,000 due and payable
on November 1, 2019
 12. Metrobank Check No. 0000000012 for P 5,000 due and payable
on Dec 1, 2019

When you issued said check, you assured me that there are more than
sufficient funds in your bank account to cover the said amount.
However, the check was returned dishonored.

Final demand is now made upon you to make good your obligation
within five (5) days from receipt hereof. Otherwise, I will be constrained
to hire the services of a lawyer to file the necessary criminal action
against you.

Please be guided accordingly.

Best Regards,

JUAN C. DELA CRUZ

Signed.
 Annex “C”

Guiguinto

Guiguinto
Pedro Castro

March 29, 2020 2

0 Signed.