Republic

of the Philippines
Department of Justice
OFFICE OF THE CITY PROSECUTOR
Cauayan City, Isabela

JENNIFER D. TALAVERA,
As represented by Ferdinand Angoluan
Complainant,

NPS Docket No. _____
Vs.
For: Batas Pambansa Blg. 22
MERLYN T. EDRADA,
Respondent.
X--------------------------------------------------------------------------------------X


COMPLAINT-AFFIDAVIT

I, FERDINAND ANGOLUAN, of legal age, Filipino and a resident of
Cabaruan, Cauayan City, Isabela, after being sworn to in accordance with
law hereby depose and state:

1. That I am the same person who executed this
Complaint-Affidavit.

2. That I am the authorized representative of Complainant
Jennifer D. Talavera, of legal age, Filipino and a resident of
Cabaruan, Cauayan City, Isabela, (See Special Power of Attorney as
Annex “A” and series)

3. That I am filing this case against MERLYN T. EDRADA,
of legal age, Filipino and a resident of Purok 5, Minante 1, Cauayan
City, Isabela.

4. That sometime in 2021 in Cauayan City, Isabela, the
respondent purchased from Jennifer D. Talavera used sacks in the
amount of Php15,900.00. (Copy of Affidavit as Annex “B”.)

5. That to pay it, she issued PNB Check No. 2000000103 in
the amount of P15,900.00 dated 12 November 2021. At the time the
aforesaid check was issued for value, the respondent assured it was
good in that the account against which to be drawn was sufficiently
funded. (Copy of the Check as Annex “C”.)

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6. That when the check was deposited the bank account of

Jennifer Talavera with Eastwest Bank, the bank issued an advice
notice that it bounced because of insufficiency of funds. (Return
Check Advice as Annex “D”.)

7. That Jennifer D. Talavera demanded from the
respondent to just pay her in cash after notifying her about the
status of her check and account. However, she did not mind the
demand. As such, a Notice of Dishonor dated 16 May 2022 was sent
which she personally received on 19 July 2022. Up to now, she has
not paid in cash. (Notice of Dishonor and Affidavit of Service as
Annexes “E” and “F”, respectively.)

8. That the respondent illegally, knowingly and willfully
drew for value PNB Check No. 2000000103 knowing at the time of
issuance the account against the check was drawn had insufficient
funds. The same account was also subsequently closed.

9. That I attest the truth of the matters herein contained
based on my own free will and volition.

IN WITNESS WHEREOF, I have hereunto set my hand this
___________ day of ______________ 2023 at Cauayan City, Isabela.


FERDINAND ANGOLUAN
Affiant
ID No. ________________

Subscribed and sworn to before me this ______ day of ______________
2023 at Cauayan City, Isabela after personally examining the witness that
he/she voluntarily executed and understood the contents of this Complaint-
Affidavit.

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