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That I,     , of legal age, married, Filipino and a resident
of c/o South Bank, Kauswagan Branch, Cagayan de Oro City, after having been
duly sworn to according to law hereby depose and say:
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1.? That I am the Loan Manager of South Bank, Kauswagan Branch, Cagayan
de Oro City. I am executing this affidavit in behalf of South Bank, being
the complainant herein.

2.? In behalf of the said Rural Bank, I am filing a formal complaint for Estafa
thru Falsification of Public Document and /or thru Forgery against
respondent Apipa G. Guro [hereinafter ´Respondentµ], a resident of
Vamenta, Carmen, Cagayan de Oro City .

3.? On October 31, 2007, Respondent using the name of, and misrepresenting
herself to be Doña Añiqa Macarambon-Bacsarpa, submitted a loan
application, purportedly signed by the Spouses, by forging their signatures
with South Bank, Kauswagan Branch, Cagayan de Oro City amounting to  !
PhP 5,000,000.00.

4.? As security for the payment of the said loan, Respondent submitted as
collateral thereof a parcel of land described in TCT No. T-178439 1 and
executed a Real Estate Mortgage over the said land in favor of South Bank.
2

5.? On December 6, 2007, the loan application amounting to Philippine Pesos:


Five Million (PHP 5,000,000.00) was approved by South Bank and the
proceeds thereof were delivered to the Respondent, receipt of which is


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evidenced by a manager·s check issued by the bank and withdrawn by the
Respondent. 3 Photocopy of the said check is hereto attached as Annex C
hereof;

6.? On January 6, 2007, South Bank found out that respondent falsified and/or

forged the above mentioned documents. It also found out that Respondent
misrepresented herself to be Doña Añiqa Macarambon-Bacsarpa when in
truth and in fact the former, as found by the bank, is Apipa G. Guro. 4

Respondent·s real identity was discovered by the bank when one of it·s
employees identified her as an acquaintance as they live in the same
barangay and is personally known to her;

7.? Respondent·s unlawful acts were discovered by the bank when the latter
tried to collect from the Spouses Bacsarpas who refused to pay on the
ground that they did not apply for a loan, much less mortgage the land
covered by subject land title in favor of South Bank;

 ? The unlawful acts by Respondent caused damage and prejudice to South


Bank in the amount of PhP 5,000,000.00, the amount released to
respondent as proceeds of the loan, including interest of twelve percent
(12%) per annum;?
?

? South Bank spent PhP 30,000.00 for attorney·s fees for filing the complaint
affidavit .?
?

10.? That I am executing this affidavit for and behalf of the South
Bank, Kauswagan, Cagayan de Oro City, being the Loan Manager thereof,
to file a formal complaint of Estafa through Falsification of Public
Documents and/or through Forgery against Apipa Guro.




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IN WITNESS WHEREOF, I have hereunto affixed my signature for and in
behalf of the complainant South Bank Kauswagan, Cagayan de Oro City this 8th
day of December 2009, at Cagayan de Oro City. „„„„

    


Affiant

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SUBSCRIBED and SWORN to before me this 8th day of December, 2009, at
Cagayan de Oro City. I hereby certify that I have personally examined the above-
named affiant and that I am satisfied that the foregoing statements were given by
him voluntarily and of his own free will.

   
Associate Prosecution Attorney II