REPUBLIC OF THE PHILIPPINES

Office of he City Prosecutor

Malate City
THE PHILOAN COMPANY INC.,
Represented herein by its
Head of Collection
MARCK G. DOMINICO
Complainant

I.S. NO.___________

--Versus

For:

REYNALDO MANUEL Y. BELTRAN

22

Violation of B.P.

Respondent
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COMPLAINT AFFIDAVIT

THE PHILOAN COMPANY, INC., (hereafter referred to as the Complainant) a

lending corporation organized and existing under the laws of the Republic of the
Philippines with business address at 231 Singalong St. Malate, Manila, is here by
represented by its Head of Collections Marck G. Dominico, of legal age, Filipino, with
he same office address abovem who afer having been sworn in accordance with law
do hereby depose and state that:
1. I am auhorized by the Complainant to file and prosecue appropriae civil
and criminal charges against clients who have outstanding loan
obligations to the Complainant. Attached as Annex A is a Corporate
Secretarys Certificae evidencing such authority
2. In my capacity as the Collection Head of the Complainant and based on
the authentic documens in my possession I came to know the respondent,
Reynaldo Manuel Y. Beltran, of legal age, Filipino and with a last known
address at 2571 Leon Guinto st. Malate, Manila where he may be served
wih subpoena and other processes of this Honorable Office.
3. Complainant hereby chages respondent for one (1) count of violation of
B.P. 22, otherewise known as, An Act Penalizing the Making or Drawing
and Issuance of a Check without Sufficient Funds or Credit and for other
Purposes, committed as follows:
A. On July 7,2013, respondent obtained a loan from complainant in the
total amount of Five Millions Pesos. The said loan is evidenced by a

REPUBLIC OF THE PHILIPPINES

Office of he City Prosecutor
Malate City
Promissory Note duly executed in favor of complainant, acopy of
which is atached as Annex B
B. As Payment for the loan accommodation, respondents dre, issued
and delivered in favor of complainan, at its business office two (2)
Post-Dated Checks (PDCs), against his bank account with assurance
and representation the the said PDCs are good and would be
covered by sufficient funds when presened for payment
C. When the following check was deposited for payment on its
maturity date, the same was dishonored and returned byy the bank
of the ground that the same was DRAWN AGAINST INFUFFICENT
FUNDS (DAIF), Copy of the said check and its dorsal side,
respectively were attached as Annoexes C and C-1 respectively.
D. Complainant for several times notified respondens of the dishono
and return of the foregoing check and demanded payment of the
above amount. Copies of several demand letters dated on different
occasions were sent to the respondents last known residence and
are attached as Annexes D, E, F and G respectively.
Likewise, copies of Registry Return Cards relative to demand letters
made are attached as Annexes D-1 and E-1 respectively.
E. Respondents, with out any justification failed and until now continue
to fail to make good of he check and to pay the amount contained
therein. Thus complainant referred the matter to its legal counsel
who sent a formal notice of dishonor and final demand letter by
personal service at the respondents aforemention last known
address. A copy of the said letter and a notice of dishonor are
attached as Annex H. Like wise, a copy of Affidavi of Service
excuted by Paulo B. Burro, the authorized messenger of the
Complainant, is hereto attached as Annex I
F. As of date, respondents unjustifiably ignored all these demands to
make good of the foregoing dishonored check and to pay the
unpaind account
4. I am executing this Complaint- Affidavit to attest to the foregoing facts
and in support of the complaint against respondent Reynaldo Manuel Y.
Beltran for violation of B.P. 22.

Affiant

REPUBLIC OF THE PHILIPPINES

Office of he City Prosecutor
Malate City
IN WITNESS WHEREOF, I have hereunto set my hand this ___ day of ___ ____. I
hereby certify that I have examined the Affiant and that I am fully satisfied
that he has volunarily executed and understood the contents of his
Complaint-Affidavit.

Administrative
Officer