REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFCE OF THE CITY PROSECUTOR
CALAMBA CITY

MARIANITA PRIZADO, ALSO KNOWN NPS DOCKET NO. ____________________

AS NITA PRIZADO,
Complainant. FOR: USE OF FALSIFIED DOCUMENT

Versus

ERNESTO E. LARA
Respondent.
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AFFIDAVIT-COMPLAINT

I, MARIANITA PRIZADO, of legal age, Filipino citizen, and a resident of San Pedro
City, Laguna, Philippines, after being duly sworn to hereby depose and say:

1. That I know personally ERNESTO E. LARA who is a resident of Blk 2 Lot 8,

Rosaflor Subdivision, Tagapo, Sta. Rosa City, Laguna, Philippines;

2. That the said ERNESTO E. LARA has in his possession a DEED OF ABSOLUTE SALE
purportedly executed by LEONILA T. ESTEBAN in his favour over a parcel of land Lot 1954-
C-9-B, PSD-04-039339, consisting of 803 Square Meters, located in Brgy. Balibago, Sta. Rosa
City and covered by Transfer Certificate of Title No, T-227453 of the Registry of Deeds for
Calamba Branch in Cakamba City, Laguna;

3. That the said DEED OF ABSOLUTE SALE is a FALSIFIED DOCUMENT and ERNEST E.
LARA knew it because it is in his possession; it is a falsified document because in the
ACKNOWLEDGMENT, at the last line there appears the following: WITNESS MY HAND AND
SEAL on this ____ day of DEC. 03 2015 _________ 20
________ CITY OF STA. ROSA. In the words CITY OF STA. ROSA which were superimposed, there
appears an erasure and the words CITY OF STA. ROSA was inserted or superimposed, without any
signature to identify the person who made the superimposition. But in his affidavit-complaint for
falsification of public document against me , Bob Salandanan and Ferdinand Lara, he attached a
Xerox copy of a Deed of Absolute Sale, but in the last line, CITY OF BINAN appears instead of
CITY OF STA. ROSA.

A Xerox copy of the Deed of Absolute sale attached to the complaint-affidavit is hereto
attached as Annex A;

4. That knowing that the Deed of Absolute Sale is falsified, the said ERNESTO E LARA used
the falsified document with intent to cause damage to me, and to BOB SALANDANAN and
FERDINAND T. LARA, in that i have to spend money for every hearing of the case where he used
the falsified document;
 5. That I am executing this Affidavit- Complaint to charge the said ERNESTO E. LARA of the
crime of using a falsified document under the last paragraph of Article 172 of the Revised Penal
Code.

5. That the last paragraph of Article 172 states:

“Article 172. FALSIFICATION BY PRIVATE INDIVIDUALS AND USE OF

FALSIFIED DOCUMENT. – The penalty of prision correctional in its medium and maximum
Periods and a fine of not more than 5,000 shall be imposed upon:

1. X x x
2. X x x

Any person who shall knowingly introduce in evidence in any judicial

proceeding or to the damage of another or who, with intent to cause such
damage, shall use any of the false documents embraced in the next preceding
article or in any of the foregoing subdivisions of this article, shall be punished
by the penalty next lower in degree.”

IN TESTIMONY WHEREOF, I have hereunto set my hand this ____ day of March 2019 at
Calamba City, Laguna, Philippines.

MARINITA PRIZADO
-Affiant-

SUBSCRIBED AND SWORN TO BEFORE me this ____ day of March 2019 at the City of
Calamba, Laguna, Philippines.

________________________________
Assistant City Prosecutor