REPUBLIC OF THE 

PHILIPPINES
OFFICE OF THE CITY PROSECUTOR
CITY OF DASMARIÑAS
      
MS. MARICRIS MACABIO MANIQUEZ,
MS. LEONILA S. VALLEJOS
Respondents

COMPLAINT AFFIDAVIT

              I, Mark Alvin Flores Jovido, Filipino, of legal age, with postal address at Blk1 Lot
32 Greenvalley Detachment, Molino 2. Bacoor Cavite, after being duly sworn in to
accordance with law, hereby depose and say:

1. That I am employed as a Legal Officer of EQGRANT LENDING CORP., a lending

company duly organized and existing under and by virtue of laws of the Philippines
with principal address at 3Roze Building, Governor’s Drive, Sampaloc 1, Dasmariñas
City, Cavite. `

2. That as Legal Officer of the company, my duties include, monitoring and collection of
delinquent accounts or past due accounts, delivery of demand letters and represent
the company in cases against delinquent borrowers of all the branches of the
company.

3. That I am authorized by the company to file a criminal case for violation of Batas Pambansa
Bilang 22 against principal borrowers Ms. Maricris Macabio Maniquez who can be served
with summons and notices at Blk J1, Lot 9, Sta. Cruz II, Dasmariñas City, Cavite and
Blk. 20 Lot 12, Sta. Fe., Area 1, Dasmariñas City, Cavite and co-maker Ms. Leonila S.
Vallejos who can be served with summons and notices at Blk. N6 Lot 2, Brgy. Emmanuel
Bergado 1, Dasmariñas City, Cavite Cavite. Attached hereto as Annex “A” the Secretary
Certificate authorizing me to represent the company.

4. On 22 February 2017, principal borrowers Ms. Maricris Macabio Maniquez and Ms.
Leonila S. Vallejos applied for a loan and was granted by EQGRANT LENDING CORP.,-
Dasmariñas City Branch in the amount of One hundred four thousand pesos
(Php104,000.00) with an interest of 5% per month for six (6) months. Ms. Maricris Macabio
Maniquez and Ms. Leonila S. Vallejos executed a Promissory Note in the amount of One
hundred four thousand pesos (Php104,000.00). Copy of Promissory Note is hereto
attached as Annex “B”.

5. Simultaneous with obtaining the loan from the our company (Dasmariñas City Branch) Ms.
Maricris Macabio Maniquez issued post-dated checks and delivered to EQGRANT
LENDING CORP. - Dasmariñas City Branch located at 3Roze Building, Governor’s Drive,
Sampaloc 1, Dasmariñas City and within the jurisdiction of this Honorable Office, PNB
Savings Bank, Dasmariñas City, Cavite Branch checks in payment of her obligation covered
by the Promissory Note.

The respondents issued a several checks and SEVEN (7) among the several checks are
the subject of this case, to wit:

PNB Savings Bank – Dasmariñas City Branch 3301038 March 30, 2017 Php 8,520.00
PNB Savings Bank – Dasmariñas City Branch 3301039 April 15, 2017 Php 8,520.00
PNB Savings Bank – Dasmariñas City Branch 3301040 April 30, 2017 Php 8,520.00
PNB Savings Bank – Dasmariñas City Branch 3301041 May 15, 2017 Php 8,520.00
 PNB Savings Bank – Dasmariñas City Branch 3301042 May 30, 2017 Php 8,520.00
PNB Savings Bank – Dasmariñas City Branch 3301043 June 15, 2017 Php 8,520.00
PNB Savings Bank – Dasmariñas City Branch 3301044 June 30, 2017 Php 8,520.00
                                                                                                                      
6. When presented to our Banco De Oro – SM 2 Dasmariñas City Branch, our company
depository bank were dishonored due to ACCOUNT CLOSED. Copies of the front and
dorsal portions of the checks are hereto attached as Annexes “C”, “D”, Ë”, “F”, “G”, “H”,
Ï.

7. Likewise, written and verbal demands to settle the obligation were made but Ms. Maricris
Macabio Maniquez refused and failed and continues to refuse and fail to pay his just and
valid obligation.

8. As a result of the failure of Ms. Maricris Macabio Maniquez, to make good of the
checks, the company was constrained to engage the services of a counsel wherein
the bank paid and amount of Php 20,000.00 plus Php 3,000.00 per appearance in the
hearings.

9. Herein attached are the Demand Letters delivered personally to the respondents on the
following dates Äpril 20, 2017, May 31, 2017 and June 21, 2017 as ANNEX “J”, “K”, “L”,
“M”.

10. I am executing this Affidavit to attest to the truthfulness of the foregoing and for the
purpose of charging Ms. Maricris Macabio Maniquez of seven (7) counts of violation
of Batas Pambansa Blg. 22.

IN WITNESS WHEREOF, I have affixed my signature this 14th day of July 2017 in
General Trias, Cavite, Philippines.
Mark Alvin F. Jovido
Affiant

SUBSCRIBED AND SWORN to before me this 14th day of July, 2017 in Dasmariñas
City, Province of Cavite. I further certify that I have personally examined the Affiant
and I am satisfied that she voluntarily executed her Counter-Affidavit and that she
understood the contents of the same.

CITY PROSECUTOR

CERTIFICATION

This is to certify that I have personally examined the affiant and I am convinced that he
has fully executed this Complain-Affidavit, read the same and understood the contents
thereof and that the allegation therein are true and correct of his personal knowledge and
based on the authentic documents in his possession.

CITY PROSECUTOR