REPUBLIC OF THE 

PHILIPPINES
OFFICE OF THE CITY PROSECUTOR
CITY OF DASMARIÑAS, CAVITE
      
Ms. Cristina L. Talay
Respondent

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 borrowers Ms. Cristina L. Talay who can be served with
summons at Mahogany Market, Kaybagal South, Tagaytay City. Attached hereto as
Annex “A” the Secretary Certificate authorizing me to represent the company

4. On 16 March 2017, principal borrower Ms. Cristina L. Talay applied for a loan and was
granted by EQGRANT LENDING CORP.,- Dasmariñas City Branch in the amount of One
hundred thousand pesos (Php100,000.00) with an interest of 5% per month for twelve
(12) months. Ms. Cristina L. Talay executed a Promissory Note in the amount of One
hundred thirty thousand pesos (Php 130,000.00). Copy of Promissory Note is hereto
attached as Annex “B”.

5. Simultaneous with obtaining the loan from our company (Dasmariñas City Branch), Ms.
Cristina L. Talay issued the post-dated checks as payment for their 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, Bank of Philippine Islands - Tagaytay City, Cavite Branch checks in payment of
their obligation covered by the Promissory Note.

The respondent issued several checks and this ONE (1) among the several checks are the
subject of this case which was deposited amounting to Php 10,834.00, to wit:

BPI - Tagaytay City Branch 763346  September 15, 2017 Php 10,834.00
                                                                         
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”.

7. Likewise, written and verbal demands through demand letters, collection follow up and
barangay hearing to settle their obligation were made but Ms. Cristina L. Talay 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. Cristina L. Talay, to make good of the checks, the company
was constrained to engage the services of a counsel wherein the company 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 personally delivered to the respondent on January
15, 2018 marked as ANNEX “D”.

10. I am executing this Affidavit to attest to the truthfulness of the foregoing and for the
purpose of charging Ms. Cristina L. Talay, of one (1) count of violation of Batas
Pambansa Blg. 22.

IN WITNESS WHEREOF, I have affixed my signature this __ day of May 2018 in

Dasmariñas City, Cavite, Philippines.
Mark Alvin F. Jovido
Affiant

SUBSCRIBED AND SWORN to before me this ____ day of May, 2018 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