REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFCE OF THE CITY PROSECUTOR
BINAN CITY, LAGUNA

BOB SALANDANAN, NPS DOCKET NO. _______________

Complainant,
FOR: FALSIFICATION OF PUBLIC
Versus DOCUMENT

ERNESTO E. LARA
Respondent.
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AFFIDAVIT-COMPLAINT

I, BOB SALANDANAN, of legal age, Filipino citizen, married and a

resident of Brgy. Dela Paz, Binan 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;

2. That the said ERNESTO E. LARA, in Binan City, Laguna,

falsified a Deed of Absolute Sale purportedly executed in his favour by
LEONILA T. ESTEBAN, selling to him 803 Square Meters of a parcel of
land, located in Brgy. Balibago, Sta. Rosa City, Laguna, then registered in
the name of Leonila T. Esteban under Transfer Certificate of Title No. T-
227453, by making it appear that LEONILA T. ESTEBAN appeared before a
Notary Public Atty. Fernando Balinado on December 03, 2015 when in fact
Leonila T. Esteban did not so appear, as she was already abroad;

3. That the proof that LEONILA T. ESTEBAN did not appear before
the Notary Public is the absence of her TIN NUMBER or PASSPORT
NUMBER in the DEED OF ABSOLUTE SALE;

A Xerox copy of the Deed of Absolute Sale is hereto attached as Annex

A;

4. That a Verification with the Office of the Clerk of Court of Binan

City, shows that Atty. Balinado did not submit a NOTARIAL REPORT to the
Clerk Of Court; a Xerox copy of the Certification by the Clerk of Court is
hereto attached as Annex B;
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5. That the records in the Bureau of Immigration shows that on

December 03, 2015, Leonila T. Esteban was not in the Philippines.

6. That I am executing this Affidavit-complaint to charge the said

ERNEST O E. LARA with the crime of falsification of Public document.

IN TESTIMONY WHEREOF, i have hereunto set my hand this ___ day

of March 2019 at Binan City, Laguna. Philippines.

BOB SALANDANAN
Affiant

SUBSCRIBED AND SWORN TO before me this ____ day of March 2019

at Binan City, Laguna, Philippines.

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Assistant City Prosecutor