May __, 2014

Dr. Corazon P. Brown

OIC - Regional Director
Region IX Regional Office
Tiguma, Airport Road, Pagadian City


COMPLAINT


COMES now Complainant RN-CT Lending Investor Corporation,
Located at Mendoza Building, Pilar Street, Zamboanga City, Represented by
Rachel Castillo y Nuega, 55 years old, married and a resident of 517D San
Jose Street, Baliwasan, Zamboanga City, after having been duly sworn to an
oath in accordance with the law do hereby accuses Julieta Pacundo y
Francisco, 49 years old, married, and a resident of Sinunuc, Zamboanga City
and employed as a Secondary School Teacher (SST-I) in the public high
school at Zamboanga City High School West, of Dishonesty Through
Falsification of Private Documents defined and penalized under article 172,
No. 2 in relation to article 171 No.2 of the Revised Penal Code, committed
as follows:

1. That on or about 02:00 oclock in the afternoon of February 6, 2014, a
certain Mrs. Julieta Pacundo y Francisco, 49 years old, Female, married,
a teacher by profession and a resident of Sinunuc, Zamboanga City,
represented herself to be a retired teacher and applied for a loan with the
RN-CT Lending Investor Corporation;

2. That Respondent Julieta Pacundo submitted the necessary documents
consisting of a photocopy of two (2) valid identification cards, e-card
GSIS, Bank Statement and a fill-up form with co-makers, to Reyna
Resuena, a loan officer of the Complainant Corporation who is tasked to
verify her loan application documents;

3. That during the validation of the bank statement (attached as ANNEX A)
of the respondent, said loan officer noticed that it contained irregularities
and was only a photocopied document and consulted her co-loan officer,
Myrna Arquiza about the questionable document and she advised Reyna
Resuena to call and inquire the corresponding bank (Union bank), that
she gave the account number of Mrs.Pacundo and it was confirmed valid
and registered under her name, but the Bank operator found no records
on any transaction to reflect the bank statement;

4. That after the discovery of loan officer Reyna Resuena of such facts, she
double checked previous bank statements handled by her and found that
the transaction listed on the bank statement of the following borrowers
are questionable as follows:

a. That the above mentioned borrowers Bank statement transaction
list are duplicates or has the same transaction list on each other and
the same whe she verified the said Bank their account numbers
were all registered on their names but the transaction listed was
faked;

b. That after such discovery the Loan officers reported to the
boss/owner herein complainant Mrs. Rachel Castillo and was
advised to secretly seek the assistance of the police;

c. That on or about 02:10 oclock in the afternoon of February 6,
2014, Loan Officers Reyna Resuena and Myra Arquiza of RN-CT
Lending Corporation assisted by PNP traffic personnelto
apprehend the culprits.

The undersigned executed this affidavit to attest the truthfulness of the
foregoing facts and to support the filing of an Administrative Case against
Julieta Pacundo y Francisco for violations of Dishonestly under Section 2 of
the DepEd order no 49, series of 2006.

The affiant further sayeth naught.

___________, this _____ day of __________, ____.


____________________________
Offended Party

SUBSCRIBED AND SWORN to before me this ___ day of _______
at _______________. I HEREBY CERTIFY that I have personally
examined the herein offended party and I am satisfied that they voluntarily
executed and understood their given affidavit.


_________________________

WITNESSES:
______________________________ ______________________________

VERIFICATION/CERTIFICATION OF FORUM SHOPPING

Republic of the Philippines )
City of Zamboanga ) S.S.

I, Rachel N. Castillo, of legal age, Filipino citizen, single and resident
of 517DSan Jose street,Baliwasan after having been duly sworn to in
accordance with law do hereby depose and say:

1. That I am the plaintiff in the above-entitled case;
2. That I have caused the preparation of the foregoing complaint and have
read the allegations contained therein;
3. The allegations in the said complaint are true and correct of my own
knowledge and authentic records;
4. I hereby certify that I have not commenced any other action or proceeding
involving the same issues in any court, tribunal or quasi-judicial agency
and, to the best of my knowledge, no such other action or claim is pending
therein;
5. That if I should learn thereafter that a similar action or proceeding has
been filed or is pending, I hereby undertake to report that fact within five
(5) days therefrom to the court or agency where the original pleading and
sworn certification contemplated herein have been filed;
6. I executed this verification/certification to attest to the truth of the
foregoing facts and to comply with the provisions of Adm. Circular No.
04-94 of the Honorable Supreme Court.
IN WITNESS WHEREOF, I have hereunto affixed my signature
this_____________day of _______ 2014, in the City of Zamboanga.



________________
Rachel N. Castillo

SUBSCRIBED AND SWORN to before me this dayof May, 2014, in the
City of Zamboanga, affiant exhibiting to me his______________________


Doc No.
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Series of 2014