REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
CITY OF MANILA

JADE REALTY CORPORATION IS NUMBER :

Complainant, __________________
-versus-
for Violation of
JANE CAMILLE ALVAREZ Batas Pambansa 22 and
Respondent. Rev Penal Code for Estafa

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COMPLAINT-AFFIDAVIT

I, Ted Cruz, of legal age, with office address at 5 Horton St, Manila City after
having been sworn to under oath do hereby depose and state that:

1. I am the Manager of and represent JADE REALTY CORPORATION,

hereinafter referred to as “Jade” in this criminal complaint.

2. Jade is a private domestic corporation incorporated under the laws of the

Philippines with its primary office at 45 Judicial St, Manila City.

3. I am executing this complaint affidavit to prove and support the complaint

that Respondent Jane Alvarez, hereinafter referred to as “Alvarez”, violated Batas
Pambansa 22 and committed the crime of estafa to the prejudice and loss of Jade as
follow.

4. Respondent Alvarez is the president and operator of Betterstone Hotel,

hereinafter referred to Betterstone Hotel. Respondent may be served with summons,
notices and other court processes at her address on record at Betterstone Hotel, 1560
Mara Clara St., Manila City

Attached is a copy of the secretary’s certificate authorizing my person to file the

criminal case against respondent Jane Camille Alvarez as Annex A

5. Betterstone Hotel is currently a lessee of Jade as Betterstone is renting a

portion of the JRC building which is owned by complainant Jade Realty.

6. As payment for the rental for the month of April 9, 2022 Alvarez issued
Check number 000123456 dated April 9, 2022 for the sum of P1,120,000.00 to Jade.

7. The check with number 000123456 was deposited at the Marcelo Street,
City of Manila branch of Jade’s bank.

8. When presented for payment the check with number 000123456 was
dishonored by the drawee bank for the reason, drawn against insufficiency of funds
(DAIF).

Attached as Annex B is a copy of check number 000123456 with the stamp DAIF
marked as Annex B-1
 9. A demand letter was sent to Alvarez to pay or make arrangements for the
payment of the dishonored check. As of the filing of this complaint and despite having
received the said demand Alvarez has only paid P500,000.00 out of the P1,120,000.00
leaving behind a balance of P620,00.00

Attached is a copy of the demand letter dated May 24, 2022 that was sent to
Alvarez as Annex C

10. The demand letter Annex C was sent by courier service LBC to the
respondent at her business address at Betterstone Hotel, 1560 Mara Clara St., Manila
City. The demand letter was received by the respondent’s authorized representative
Hydee Tan on May 26, 2022.

Attached is a copy of the proof of mailing of the demand letter dated May 24,
2022 as Annex C-1 and the proof of receipt as Annex C-2.

IN WITNESS WHEREOF, I hereunder affix my signature on this

___ day of June 2022 in the City of Manila.

Ted Cruz
Complainant

SUBSCRIBED AND SWORN to before me, this ___ day of June

2022 in the City of Manila.

CERTIFICATION
I hereby certify that I have personally examined the Affiant and that I am satisfied
that he voluntarily executed and understood his affidavit

_________________________
Assistant City Prosecutor