REPUBLIC OF THE 

PHILIPPINES
OFFICE OF THE CITY PROSECUTOR
CITY OF DASMARIÑAS
      
MS. GERALDINE JOY C. SALCEDO
Respondent

COMPLAINT AFFIDAVIT

              I, 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 Ms. Geraldine Joy C. Salcedo, Filipino, who can be served with
summons and notices at Blk., 7, Lot 1, Marcos Alvarez Street., Talon V, Las Piñas City,
Metro Manila. Attached hereto as Annex “A” the Secretary Certificate authorizing me
to represent the company.

4. On 19 February 201, Ms. Leticia C. Salcedo and Ms. Geraldine Joy C. Salcedo applied
for a loan and was granted by EQGRANT LENDING CORP., - Dasmariñas City, Cavite
Branch in the amount of One hundred thirty thousand pesos (Php130,000.00) with an
interest of 5% per month for six (6) months. Ms. Leticia C. Salcedo and Ms. Geraldine
Joy C. Salcedo executed a Promissory Note in the amount of One hundred sixty nine
thousand eight pesos (Php169,008.00). Copy of Promissory Note is hereto attached as
Annex “B”.

5. Simultaneous with obtaining the loan from the lending company (Dasmariñas City Branch)
Ms. Geraldine Joy C. Salcedo 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, Banco De Oro –
Marcos Alvarez Avenue, Las Piñas Branch checks in payment of her obligation covered by
the Promissory Note.

The respondent issued several checks and this TWO (2) among the several checks are the
subject of this case which was deposited amounting to Php 28,168.00, to wit:

BDO – Marcos Alvarez, Ave., Las Piñas Branch 13667 April 05, 2018 Php14,084.00
BDO – Marcos Alvarez, Ave., Las Piñas Branch 13668 April 20, 2018 Php14,084.00
                                                                                                                          ____________________
                                                                                                                       TOTAL:   
Php28,168.00                                                                                                      
6. When presented to our Banco De Oro – 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 Ms. Geraldine
Joy C. Salcedo 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. Geraldine Joy C. Salcedo, to make good of her 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 2,000.00 per appearance in the hearings.

9. Herein attached are the Demand Letters delivered personally to the respondent on April 13,
2018 and on April 26, 2018 as ANNEX “E”, “F”.

10. I am executing this Affidavit to attest to the truthfulness of the foregoing and for the
purpose of charging Ms. Geraldine Joy C. Salcedo, of two (2) counts of violation of
Batas Pambansa Blg. 22.

IN WITNESS WHEREOF, I have affixed my signature this ____ day of May 2018 in
General Trias, Cavite, Philippines.
Alvin Jovido
Affiant

SUBSCRIBED AND SWORN to before me this ____ day of April, 2018 in Dasmariñas
City, Province of Cavite. I further certify that I have personally examined the Affiant
and I am satisfied that he voluntarily executed his Counter-Affidavit and that he
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