REPUBLIC OF THE PHILIPPINES)

Pasay City ) SS.

ABC DEF
Plaintiff, Criminal Case No. _____
For Estafa and B.P 22

vs.

GHI JKL
Respondent

COMPLAINT AFFIDAVIT

COME NOW defendants, by counsel and unto this Honorable Court, most respectfully move to
quash the information filed against the defendants on the ground of lack of jurisdiction over the
subject matter.

ARGUMENTS

Defendants are indicted for committing the crime of " BP 22 and Estafa under Article 514
(d) of the Revised Penal Code ".

Defendants, however, most respectfully submit that this Honorable Court lacks
jurisdiction over the subject matter of the offense for the reason that That the facts charged don’t
constitute an offense.

It is admitted that the Defendant obtained a loan from the plaintiff, however, the cheque
in question was not yet due at the time the complaint was filed and was funded within five (5)
days from the time it has been due and demandable.

PRAYER

WHEREFORE, it view of all the foregoing, it is most respectfully prayed that the information be
quashed, and defendants discharged.

Other relief just and equitable are likewise prayed for.

Pasay City Philippines, December 18, 2020

Atty. WXY Z
Counsel for the Accused

COPY FURNISHED:

OPPOSING COUNSEL