Republic of the Philippines )

City of Paranaque )S.S

Affidavit of Complaint

I, Lovella M. Tantoco, of legal age Filipino, with office address at #888

Delbros Avenue, Pascor Drive, Queensway Subdivision, Brgy. Sto Nino,
Paranaque City. after having sworn in accordance with law herby depose and state
that:

1. I am designated as Credit and Collection Manager of Delbros Waterfront

Chassis Leasing Corporation (DELWATER), a corporation duly organized
and existing in accordance with the laws of the Republic of the Philippines;
2. On April 13, 2009 and March 12, 2017, a contract of lease was entered into
by herein plaintiff and defendant corporation 4Cast Represented by
Cresenciano A. Banaag with principal business address at Blk 18, Lot 18
and 20 BF Martinville, Manuyo Dos, Las Pinas City;
3. On May 7, 2012, DELWATER sent Demand Letter via registered mail
signed by its Comptroller JM Borja and Atty. Lorenzo Bigayan External
Counsel;
4. On September 17, 2014, DELWATER sent another Demand Letter through
its Credit and Collection Manager Ma. Nina Silang and Atty. Patrick F.
Duran External Counsel;
5. 4Cast Logistics Co Inc sent a reply questioning the charges due to the
alleged wear and tear of chassis. DELWATER responded through its Credit
and Collection Manager Ma. Nina Silang and President Jose Paolo Delgado
agreed to give herein defendant 4Cast Logistics a discount of 34% that
would allow them to pay Php 125, 256.96 but the latter defaulted in
payment;
6. On November 27, 2015, DELWATER sent another Demand Letter through
its Credit and Collection Manager Ma. Nina Silang and Atty. Patrick F.
Duran External Counsel demanding herein defendant to pay Php 189,
688.96;
7. On September 13, 2016, DELWATER sent another Demand Letter through
its External Counsel Atty. Patrick F. Duran demanding herein defendant to
pay Php 189, 688.96;
8. On November 22, 2016, DELWATER sent another Demand Letter entitled
“1st Demand Letter” through its new Credit and Collection Director Imelda
Sorilla and Atty. Patrick F. Duran External Counsel demanding herein
defendant to pay Php 189, 688.96;
9. On November 28, 2016, DELWATER through Credit and Collection
Assistant Bemla Remoto sent a follow up e-mail regarding the legal
obligation of herein defendant but no response was received from the latter;
10.On December 29, 2016, DELWATER sent another Demand Letter entitled
“2nd Demand Letter” through its new Credit and Collection Director Imelda
Sorilla and Atty. Patrick F. Duran External Counsel demanding herein
defendant to pay Php 189, 688.96;
11.On January 19, 2017, DELWATER through Credit and Collection Assistant
Bemla Remoto sent a follow up e-mail regarding the legal obligation of
herein defendant but again no response was received from the latter;
12.On January 31, 2017, DELWATER through its Non-Performing Assets
Supervisor Celedonio Viray Jr., meet with the secretary of Mr. Cresencio
Banaag and discussed the payment of their obligation;
13.On February 7, 2017, Mr. Celedonio Viray Jr. followed up with the secretary
of Mr. Cresencio Banaag regarding the payment of their obligation but the
latter said that they have already referred this matter to their Legal
Department;
14.I am executing this Affidavit to attest the truth of the foregoing and for all
legal intents and purposes it may serve.

IN WITNESS WHEREOF, I have hereunto set my hand _____ day of 2017 at

_____________.

___________________

Lovella M. Tantoco
Affiant

SWORN AND SUBSCRIBED to before me this ____ day of ___________,

2017 the affiant personally appeared and exhibited his competent evidence of
__________.

Doc No. ________

Page No. _________

Book No. __________

Series of 2017