Republic of the Philippines)

Dipolog City . . . . . . . )s.s.

JUDICIAL AFFIDAVIT-COMPLAINT

I, JUFEL E. ACORIN, married, Filipino, and a resident of Purok

Basak, Barcelona, Dapitan City, Zamboanga del Norte, a self-employed by
profession, after having been duly sworn to an oath in accordance with the
law, and in answers to the questions asked of me, do hereby depose and
say:

That this examination is conducted and supervised by Atty. Eulogio

L. Lagudas, Jr. in his private Law Office located at Back Capitol Site,
Dipolog City, in the language known and understood by me;

That I am fully conscious and do so under oath in answering the

questions asked of me. That I likewise understood that I may face criminal
liability for false testimony or perjury in giving untruthful answers to the
question asked of me.

QUESTIONS & ANSWERS

1. Q. What is your highest educational attainment?
A. A college undergraduate;

2. Q . What is your line of work?

A. I am self-employed with mixed line of works such as construction
leadman, farmer, fishpond operator, and others;

3. Q. What is your purpose in executing this Judicial Affidavit-Complaint?

A .I am filing cases for estafa or swindling against both ALBERT E.
TONQUIN and DANNY LUTOC, both residents of Polo, Dapitan City;

4. Q. What is your connection with them?

A. ALBERT E. TONQUIN is my agent in operating a fishpond, my
broker in selling of fingerlings and fish harvest. DANNY LUTOC is
the caretaker of my fishpond operation;

5. Q. How about you, what is your function being the principal in

operating a fishpond?

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 A. I am the financer of our fishpond undertaking located in Dampa,
Polo, Dapitan City. I rented the fishpond from its owner by 40/60
sharing. Meaning 40% of the sales goes to the owner, while 60%
thereof goes to me after deductions of expenses;

6. Q. What happened to your fishpond operation?

A. When we started our operation last October 2021, expectedly the
harvest season will start after 2 months depending on the sizes
that will be ordered by the customers. However, they, thru
concerted efforts, failed to report and remit to me the amount of
money I was supposed to receive from the sales of fish they
harvested from the fishpond;

7. Q. How many times did they harvest and sell fish from the fishpond?
A. Several times from December 27, 2021 up to now but they only
gave me 2 times. One in the amount of P10,000 and the second one
P12,000;

8.Q. When?
A: Sometime in the month of January 2022;

9. Q. How much is the amount you are supposed to receive?

A. More than P400,000.00;

10. Q. How did you arrive at that estimate?

A. Out of 258,000 bangus fry that we cultured, it would produce
around 70% survival rate which it would make sales in the amount of
P400,000 to the least;

11. Q.Do you have documentary proof showing their sale transaction of the
fish harvest?
A: Yes, I have here with me documents to show the list of the
transactions;

Counsel: We pray to mark these documents as Exhibits “A” to “G” for

the prosecution.

12.Q.What are your comments on that list?

A.If I didn’t send them a demand letter from my lawyer, they did not
provide me with the list. Nevertheless, they put an unreasonable
amount on the expenses to appear that they did not swindle me. They
did not remit any amount except those in the month of January 2022 as
I had said earlier;

13. Q. Do you have a copy of the letter from your lawyer?

A. Yes, I have it, here it is;
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 Counsel: We pray to mark this letter as Exhibit “H”.

14. Q. Aside from this letter, what other remedy or action did you take
against the respondents?
A. I summoned them before the Office of the Brgy. Chairman in Polo,
Dapitan City. Here is the copy Certificate to File Action;

Counsel: We pray to mark this certificate as Exhibit “I” for the

prosecution, your Honor;

IN WITNESS WHEREOF, I have hereunto affixed by signature this

__________________, in the City of Dipolog, Philippines.

JUFEL E. ACORIN
Affiant
COMELEC ID with photo

SUBSCRIBED AND SWORN TO before me this

_________________, affiant showing his competent evidence of
identity as indicated below his name.

Attestation

I hereby swear that I faithfully recorded or caused to be

recorded the questions I asked and the corresponding answers that
the witness gave. Neither I nor any other person then present or
assisting him coached the witness regarding the latter’s answer.
______________________, Dipolog City, Philippines.

ATTY. EULOGIO L. LAGUDAS, JR.

Roll of Attorneys No. 56396

SUBSCRIBED AND SWORN TO before me this

________________, attesting counsel showing his competent evidence
of identity as indicated below his name.
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