Republic of the Philippines

Office of the City Prosecutor

City of Ilagan, Isabela
MERYLJAN D. ANGANGAN,
Complainant,
CRIMINAL CASE NO. _____
- versus - FOR: VIOLATION OF ARTICLE 315
Paragraph 2 (e)

CARL FRANCIS A. ALINDAYU,

Respondent.
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COMPLAINT-AFFIDAVIT

The complainant is MERYLJAN D. ANGANGAN, of legal age, single, Filipino, and for
purposes of this criminal complaint, with postal address at Purok 1, Barangay Alibagu, City of
Ilagan, Isabela;

The respondent is CARL FRANCIS A. ALINDAYU, of legal age, single, Filipino, and with the
following address, where summons and notices may be served, to wit: Purok 2, Barangay
Alibagu, City of Ilagan, Isabela;

This is a criminal complaint for violation of Article 315 Paragraph 2 (e) of the Revised
Penal Code involving the sum of FIFTY THOUSAND (P50,000) PESOS arising from fraud by the
respondent.

After having been duly sworn to according to law, I here depose and say:

1. That this complaint-affidavit is being filed to charge CARL FRANCIS A. ALINDAYU, of the
crime of ESTAFA under Article 315 of the Revised Penal Code, committed as follows;

2. That the respondent, is in need of services of a Caterer for the celebration of his
parents’ Golden Wedding Anniversary to be held on the 13 th day of May 2021 at
Dreamwave Hotel, City of Ilagan, Isabela;

3. That I, Meryljan D. Angangan is the proprietor/manager of Mije’s Cuisine Restaurant

with business address at Barangay Alibagu, City of Ilagan, Isabela. Further, Mr. Carl
Francis A. Alindayu necessitate the catering services of my restaurant and entered into
an engagement to provide service in the upcoming Wedding Anniversary of his parents.

4. On the terms of our agreement, I required him to pay FIFTY PERCENT (50%) initial
payment of the catering service amounting to TWENTY-FIVE THOUSAND (P25,000)
PESOS and another FIFTY PERCENT (50%) amounting to TWENTY-FIVE THOUSAND
(P25,000) PESOS upon the completion of the catering service, the respondent agreed
and paid the initial payment on the date of our agreement;

5. On the day of the catering, I finished all the preparations in the venue and rendered all
the necessary assistance during and after the event. However, upon the completion of
 the catering service, the respondent refused to pay his balance of TWENTY-FIVE
THOUSAND (P25,000) PESOS;

6. That due to the cancellation, it inflicted damages on the inventory of my restaurant, and
the respondent refused to answer my calls, and pay his remaining balance;

7. Based on the foregoing, the respondent Carl Francis A. Alindayu committed the crime of
estafa punishable under the Article 315 Paragraph 2 (e) of the Revised Penal Code. He
defrauded me to believe that he agreed to pay the other FIFTY PERCENT of the catering
service. This constitutes statutory estafa as defined in our laws.

WHEREFORE, premises considered, it is respectfully prayed that after notice and hearing, the
respondent be indicted for ESTAFA to protect the right/interest of the complainant to recover
her claim of FIFTY THOUSAND (P50,000) PESOS, plus attorney’s fees of TWENTY THOUSAND
(P20,000) PESOS, and costs of suit.

CITY OF ILAGAN, ISABELA, June 1, 2021

MERYLJAN D. ANGANGAN
Complainant
ID: ____________________
Assisted By:

ATTY. JOHNSON KHUFRA M. MINO

Counsel for the Complainant
2nd Floor, ACE Building, Tanguile St.,
City of Ilagan, Isabela

SUBSCRIBED AND SWORN TO BEFORE ME this ____ day of _______________ in Roxas,

Isabela, Philippines. And that I hereby certify that I have personally examined the herein
affiand; that I am fully convinced that he/she voluntarily executed and understood their
criminal complaint.

_______________________
Prosecutor