Republic of the Philippines)

Quezon City )S.S.

COMPLAINT - AFFIDAVIT

I, , of legal age, Filipino, with postal address at c/o X

Trade, Inc., 23F, The Orient Square, Emerald Avenue, Ortigas Center,
Pasig City, after being duly sworn in accordance with law, hereby
depose and state that:

1. I am the President of X Trade, Inc. (X, for brevity), a corporation

duly organized and existing under Philippine laws with principal
place of business at 23 F, The Orient Square, Ortigas Center, Pasig
City;

2. One of my principal duties is to undertake and pursue collection

efforts with respect to the corporations delinquent accounts,
including the filing and prosecution of the necessary criminal
complaints against responsible persons connected with said
accounts. For reference purposes, attached hereto is a copy of the
Secretarys Certificate of X evidencing such authority ( Annex A);

3. On 8 December 2007, (hereinafter referred to as the respondent)

applied for and was granted a loan by X in the principal amount of P
150,000.00, payable on or before 31 December 2007;

4. As payment for the loan obligation, respondent issued, signed and

delivered to X the following post-dated check:

Drawee Bank Check No. Date of Check Amount

Union Bank 00031245022 28 Dec. 2007 P150,000.00

( Alabang Town Center, Muntinlupa City)

For reference purposes, attached hereto as Annex B is a copy

of the above-mentioned check;

5. Upon presentment for payment of the said check at the drawee

bank (Union Bank) at its branch located at the Alabang Town
Center, Alabang, Muntinlupa City, the check was
dishonored/returned by the drawee bank (Union Bank) for the
reason Account Closed;

6. Several demands were made by X upon respondent for the

payment of the face value of the said check. These demands were
reiterated in the demand letter dated 13 July 2009 sent by the
counsel of X to respondent. Despite receipt of the letter, respondent
failed and refused, and still fails and refuses, to comply with the
demand therein for the payment of the face value of the check
within five (5) banking days from said receipt. A copy of the
demand letter is hereto attached as Annex C for reference
purposes. Likewise, attached hereto as Annex C-1 is the
Certification issued by the Philippine Postal Corporation (National
 Capital Region) attesting to the fact that the demand letter was
received by an authorized representative of respondent;

7. Such failure or refusal of respondent to pay or make arrangements

for the settlement of the face value of the bounced check has
resulted in manifest prejudice to, and damage of, X. Further, X was
compelled to incur litigation and other related expenses as a result
of respondents adamant failure to satisfy Xs plainly valid, just and
demandable claim;

8. I am executing this complaint-affidavit in order that a criminal case

for violation of Batas Pambansa Blg. 22 and/or Estafa may be filed
against respondent X R. CERTEZA for the purpose of recovering the
face value of the above-mentioned check, plus the corresponding
interest and penalty charges thereon, as well as any and all legal
costs (including, but not limited to, attorneys fees) which may
have been incurred by X in connection with this account;

9. To the best of my knowledge and information, respondent X R.

CERTEZA may be served with notices and other processes of this
Honorable Office at 801 Heart Tower, Valero St., Salcedo Village,
Makati City.

IN WITNESS WHEREOF, I have hereunto set my hand

this__________at___________.

AFFIANT

SUBSCRIBED AND SWORN TO before me this

_______________at______________________.

INVESTIGATING PROSECUTOR