REPUBLIC OF THE 

PHILIPPINES
OFFICE OF THE CITY PROSECUTOR
CITY OF DASMARIÑAS
      
MR. RANDY C. MELMIDA, MARIFEL R. VILLA
AND LOURDES F. BEROS
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 Mr. Randy C. Melmida and Marifel R. Villa Filipinos
who can be served with summons and notices at Blk 78, Lot 17, Parklane Country Homes,
San Francisco, General Trias City, Cavite and co-maker Lourdes F. Beros who can be
served with summons and notices at Blk. 76 Lot 126, Parklane Country Homes, San
Francisco, General Trias City, Cavite. Attached hereto as Annex “A” the Secretary
Certificate authorizing me to represent the company.

4. On 22 February 2017, principal borrowers Mr. Randy C. Melmida and Marifel R. Villa and
co-maker Lourdes F. Beros applied for a loan and was granted by EQGRANT LENDING
CORP.,-Dasmariñas City Branch in the amount of Ninety Six Thousand Pesos
(Php96,000.00) with an interest of 5% per month for four (4) months. Mr. Randy C. Melmida
and Marifel R. Villa and co-maker Lourdes F. Beros executed a Promissory Note in the
amount of Ninety six thousand pesos (Php96,000.00). Copy of Promissory Note is
hereto attached as Annex “B”.

5. Simultaneous with obtaining the loan from the our company (Dasmariñas City Branch) Mr.
Randy C. Melmida and Ms. Marifel R. Villa convinced me to take the post-dated checks of
their co-maker, Lourdes F. Beros which were issued 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, Sterling
Bank of Asia, Imus, Cavite Branch checks in payment of his obligation covered by the
Promissory Note.

The respondents issued a several checks and TWO (2) among the several checks are the
subject of this case amounting to Php 48,600.00, to wit:

Sterling Bank of Asia - Imus City, Cavite Branch 5350303 May 22, 2017 Php24,300.00
Sterling Bank of Asia - Imus City, Cavite Branch 5350304 June 22, 2017 Php24,300.00
                                                                                                                          
 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”.

7. Likewise, written and verbal demands to settle the obligation were made but Mr. Randy C.
Melmida, Marifel R. Villa and Lourdes F. Beros refused and failed and continues to
refuse and fail to pay his just and valid obligation.

8. As a result of the failure of Mr. Randy C. Melmida, Marifel R. Villa and Lourdes F.
Beros, 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 May 31, 2017, June 06, 2017 and June 30, 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 Mr. Randy C. Melmida, Marifel R. Villa and Lourdes F. Beros, of
two (2) 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