REPUBLIC OF THE 

PHILIPPINES
OFFICE OF THE CITY PROSECUTOR
CITY OF DASMARIÑAS
      
JANICE TAGUINES MOLLANEDA
Respondents

COMPLAINT AFFIDAVIT

              I, Mark Alvin Flores Jovido, Filipino, of legal age, with postal address at Blk1 Lot
32 Green Valley 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 borrower Ms. Janice Taguines Mollaneda who can be served
with summon at Blk. 2 Lot 3, Phase 5, Lancaster Residences, Brgy. Alapaan II, Imus
City, Cavite Attached hereto as Annex “A” the Secretary Certificate authorizing me to
represent the company.

4. On 4 March 2017, principal borrower Ms. Janice Taguines Mollaneda applied for a loan
and was granted by EQGRANT LENDING CORP.,-Dasmariñas City Branch in the amount
of Two hundred thousand pesos (Php200,000.00) with an interest of 5% per month for
six (6) months. Ms. Janice Taguines Mollaneda executed a Promissory Note in the
amount of Two hundred sixty thousand pesos (Php260,000.00). Copy of Promissory
Note is hereto attached as Annex “B”.

5. Simultaneous with obtaining the loan from the our company (Dasmariñas City Branch) Ms.
Janice Taguines Mollaneda issued and delivered the post-dated checks as payment for
her amortization 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, China Bank Savings Tanzang Luma, Imus, Cavite Branch checks
in payment of her obligation covered by the Promissory Note.

The respondents issued a several checks and these initial SIX (6) among the several
checks are the subject of this case amounting to Php 131,502.00, to wit:

China Bank Savings – Imus, Cavite Branch 12187  May 30, 2017 Php 21,917.00
China Bank Savings – Imus, Cavite Branch 12188  June 15, 2017 Php 21,917.00
China Bank Savings – Imus, Cavite Branch 12189  June 30, 2017 Php 21,917.00
China Bank Savings – Imus, Cavite Branch 12190  July 15, 2017 Php 21,917.00
China Bank Savings – Imus, Cavite Branch 12191  July 30, 2017 Php 21,917.00
China Bank Savings – Imus, Cavite Branch 12193  Aug. 15, 2017 Php 21,917.00
                                                                                                                     
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”.
 7. Likewise, written and verbal demands through demand letters and collection follow up to
settle the obligation were made but Ms. Janice Taguines Mollaneda refused and failed
and continues to refuse and fail to pay their just and valid obligation.

8. As a result of the failure of Ms. Janice Taguines Mollaneda, 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 on June 16, 2017 and June
21, 2017 as ANNEX “I” and ANNEX “J” respectively.

10. I am executing this Affidavit to attest to the truthfulness of the foregoing and for the
purpose of charging Ms. Janice Taguines Mollaneda, of six (6) counts of violation of
Batas Pambansa Blg. 22.

IN WITNESS WHEREOF, I have affixed my signature this _____ day of August 2017
in Dasmariñas City, Cavite, Philippines.
Mark Alvin F. Jovido
Affiant

SUBSCRIBED AND SWORN to before me this ______ day of August, 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