December 14, 2017

PRESIDENTIAL ACTION CENTER

Malacañang Palace
8888
J. P. Laurel Avenue
San Miguel, Manila

Thru:
The Honorable Service Commission
Amas, Kidapawan City

Sir/Madam:

ADMINISTRATIVE COMPLAINT
For DISHONESTY, FALSIFICATION OF
PUBLIC DOCUMENTS AND VIOLATION OF LAW

AFFIDAVIT COMPLAINT

I, CARMELITA BAYAWANON, of legal age, single, Filipino and a

resident of Ilian, Magpet, Cotabato, after being been duly sworn to
in accordance with law do hereby deposed and say;

1. That I am filing a complaint for herself and all heirs of the late
Indoy Bayawanon and Abayon Angit, by virtue of Special Power of
Attorney executed by the children of Spouses of Indoy Bayawanon
and his wife, who died on January 20, 1998 and on July 12, 1983,
respectively at Ilian, Magpet, Cotabato, respectively against the
following person to wit;

2. Lina Leonida, now Mrs. Lina Leonida Tolentino, Filipino, Public

School teacher at Lake Agco, Kidapawan City, but with residence
at Jose Dans Street, Kidapawan City, where she may serve with
Notices and Summons and other processes;

3. The respondent, Philippine National Bank, Davao City Branch,

for short, trough CARP Manager Imelda Sepe, (PNB- Davao) Davao
City a Banking Institution duly Organized in accordance with laws
of the Philippines and which was responsible for the foreclosure of
the land of Spouses Bayawanon (now deceased) with National
Office PNB Scolta Building, Manila, for purposes of this complaint has
a branch Office at Davao City where it can be serve with notice
and summons and other processes;

4. The Provincial Sheriffs of Cotabato, who sold to the defendant

PNB, Davao Branch, Davao City, being the highest bidders which
sheriffs sale is void from the beginning, pursuant to the Sugar
Restitution Law known as Republic Act No. 7202- which was
approached on February 29, 1992, which it provide on Section 3,
the following Sec. 3, Copy of which is hereto attached as Annex
“____”

5. That pursuant to the Agreement of the late Spouses Indoy

Bayawanon and Abayon Angit, and Lina Leonida now Lina Leonida
Tolentino, the Agreed Lease Rental s was for the amount of Five
Thousand (P5,000.00) pesos, per year per hectare for the Agricultural
land of Lot No. 6996, Pls-59 with OCT No. V-795, now TCT No. 77517
with area of 5,1633 hectares;

6. That the respondent Lina Leonida Tolentino have not paid for
the rentals of said property to spouses Indoy Bayawanon or his heirs,
since 1976 up to the present time;

7. At Five Thousand per hectare or a total of Twenty Five

Thousand (P25,000.00) plus hectare per year excluding legal interest
and other charges and Lina Leonida Tolentino failed to pay despite
repeated demands, which respondent refuse to pay up to the
present time;

8. Considering that respondent Lina Leonida Tolentino likewise

failed to pay her account to PNB, the Heirs of Indoy Bayawanon
shall suffer the loss of their lands through the fault of Lina Leonida
Tolentino;

9. The Complainant and heirs of Spouses Bayawanon surely and

clearly deprived them of the value of their land and the means to
support their families which at its present Market Value of the land
amounted at a price of One Million (P1, 000,000) per hectare or Five
Million (P5, 000,000) for the total value of Five hectares which we are
demanding to compel her to pay and the additional amount plus
20% plus additional fees if not settled out of the Court.

10 . That we are requesting that all benefits of Mrs. Lina Leonida

Tolentino be forfeited as Public School Teacher of DepEd,
Kidapawan City, that through her misrepresentation and dishonesty,
in securing the signature of our illiterate late grandfather and father
respectively to the damage and prejudice of all heirs of Indoy
Bayawanon losing their property and failure to rentals

11 . That I am executing this affidavit to attest the truthfulness of

the foregoing facts.

12 . AFFIANT SAYETH NAUGHT.

IN WITNESS WHEREOF, I have hereunto set my hand below this

18th day of December 2017 at Kidapawan City, Philippines.

CARMELITA BAYAWANON
Complainant/Affiant
Passport No. EC2527032
Issued by DFA

SUBSCRIBED AND SWORN to before me this 18th day of

December, 2017 at Kidapawan City, Philippines, I likewise certify that
I have personally examined the herein Affiant and I am convinced
that she voluntarily executed the statement and fully understood the
contents of the same.

Doc No. ______;

Page No. _____;
Book No. _____;
Series of 2017.