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REPUBLIC OF THE PHILIPPINES) CITY OF MALOLOS )s.s.

COMPLAINTAFFIDAVIT
I, Maria Antonina S. San Diego of legal age, Filipina, and with residence at 65 Lugam City of Malolos, Bulacan, after having been sworn to in accordance with law, do hereby depose and state that: 1. Evelina Baldomesa was a client of Rosario Victoria who is my sales agent to whom I entrusted some pieces of jewelry on consignment basis. Sometime in June 2011 she went to see me in my house together with Rosario Victoria, to talk to me about paying the jewelry directly to me instead of paying it through Rosario Victoria. The three of us, Rosario Victoria and Evelina Baldomesa and I agreed to such arrangement. For which she issued me several checks amounting to_________ RCBC Savings Bank of Malolos. In our first transaction as a direct client, she paid me an amount of P50, 000.00 through bank deposit made by Ms. Victoria, this was on June 2011 and another P5,000.00 on the same month of the same year again through Ms. Victoria. However, upon promising me that full payment of what she owes me amounting to P855, 000.00 will be made in July 2011 nothing came after, and all the checks she issued were dishonored by the bank. Photocopy of the issued checks is attached as Annex A Bank / Check # Date Amount Status

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On August 2011 she issued a check as payment of P810, 000.00 ( ) but again, was dishonored by the bank. Photocopy of the issued check is attached as Annex B Bank / Check# Date Amount Status

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When the check was dishonored, I promptly went to her house to inform her and she promised me that she will pay. On October 2011 she paid an amount of P45,000.00 and signed a promissory note to indicate her intention to pay. Photocopy of the promissory note is attached as Annex C

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Then again, she never made good of her promise. In view of Evelina Baldomesa obstinate refusal to pay after texting her, calling her regarding her promise to pay and the continuous bank dishonoring her checks, I referred the matter again to my legal counsel, who accordingly sent two DEMAND LETTERS to Ms. Baldomesa, to pay her outstanding obligation specifically the P810,000.00.

7. Despite her receipt of the DEMAND LETTER dated___ , Ms. Baldomesa still failed to pay her outstanding obligations and still fail and refuse to pay her indebtedness. The RCBCSavings Bank of Bulacan checks she issued for the months of May to July 2011 and Equicom Bank () are already closed accounts. 8. As result of nonpayment of the outstanding obligations of Ms. Baldomesa I suffered damages of lost in income in the amount of P 810,000.00 9. Also, as a result of Evelina Baldomesa issuance of worthless checks, I suffered actual damages in the amount P_____ plus interest thereon as well as moral damages and attorneys fee. 10. In view of the foregoing, I hereby execute this affidavit to initiate a complaint for fourteen () counts of violation of B.P. Blg. 22 or the Bouncing Checks Law against Evelina Baldomesa who resides at #232 Brgy Santiago City of Malolos Bulacan. All allegations in this affidavit are based on my personal belief and knowledge of the said facts.

Maria Antonina S. San Diego Affiant

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