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REPUBLIC OF THE PHILIPPINES


CITY PROSECUTOR OFFICE
HALL OF JUSTICE, BACOLOD CITY
-oOo-


TILDA NAGA-UGTAS,
Complainant,

- versus - Criminal Case No. 014-01-01
to 014-01-024
For: VIOLATION
OF B.P. BLG. 22

SPOUSES RONNIE & BLESS YU,
Respondent.
X ------------------------------x



ACCUSATORY AFFIDAVIT

I, TILDA NAGA-UGTAS, of legal age, single, Filipino, and a
resident of Brgy. Bata, Bacolod City, Philippines, after subscribing to an
oath hereby depose and state:

That on January 1, 2012, SPOUSES RONNIE & BLESS YU issued,
from their joint bank account with account number 003162, in my favor
seven (7) Land Bank of the Philippines (LBP) Checks, to wit:


LBP Check No. Date Amount
1. 0000564254 March 1, 2012 Php 90,000
2. 0000564255 March 15, 2012 90,000
3. 0000564256 April 1, 2012 90,000
4. 0000564257 April 15, 2012 90,000
5. 0000564258 May 1, 2012 90,000
6. 0000564259 May 15, 2012 90,000
7. 0000564260 June 1, 2012 60,000
TOTAL Php 600,000





2
That on September 1, 2012, SPOUSES RONNIE & BLESS YU again
issued, from the same bank account, in my favor seventeen (17) Land
Bank of the Philippines (LBP) Checks, to wit:

1. 0000564271 September 15, 2012 60,000
2. 0000564272 October 1, 2012 60,000
3. 0000564273 October 15, 2012 60,000
4. 0000564274 November 1, 2012 60,000
5. 0000564275 November 15, 2012 60,000
6. 0000564276 December 1, 2012 60,000
7. 0000564277 December 15, 2012 60,000
8. 0000564278 January 1, 2013 60,000
9. 0000564279 January 15, 2013 60,000
10. 0000564280 February 1, 2013 60,000
11. 0000564281 February 15, 2013 60,000
12. 0000564282 March 1, 2013 60,000
13. 0000564283 March 15, 2013 60,000
14. 0000564284 April 1, 2013 60,000
15. 0000564285 April 15, 2013 60,000
16. 0000564286 May 1, 2013 60,000
17. 0000564287 May 15, 2013 40,000
TOTAL Php 1,000,000

That all of said Check issuances are in the Sum Total of One
Million Six Hundred Thousand Pesos (Php 1,600,000), as payment of
said Spouses in my favor, for the cash loan of Two Million Pesos (Php
2,000,000) which I have generously lent them in June 1, 2010 for the
construction of their house. Out of the total cash loan, Spouses have only
paid Four Hundred Thousand (Php 400,000) leaving an unpaid amount
of One Million Six Hundred Thousand Pesos (Php 1,600,000) for which
the said Checks were issued in my favor.

But when each LBP check was deposited for presentment for
payment and/or clearing, each of the twenty-four (24) check was
dishonored and returned for the reason DRAWN AGAINST
INSUFFICIENT FUND (DAIF) as shown on the face of each check; each
worthless check is also hereto attached as Annexes A to X hereof.

Oral and written demands were made upon the Spouses Yu. A
demand letter dated May 25, 2013 sent by registered mail under
Registry Receipt No. 012345 and a return card showing that they
received the subject demand is hereto attached as Annex Y; the
Registry Receipt, Annex Z; and the Mail Return Card, Annex AA
hereof.

3
But despite repeated demands any redemption and/or full
payment to each of the bum checks of the sum total of all aforesaid
checks were refused or unreasonably ignored by Sps. Yu to the damage
and prejudice of herein Complainant.

Further, respondent suffers additional damage and prejudice in
the sum of One Million Pesos (Php 1,000,000) in terms of unpaid
compounded interest, and for Five Hundred Pesos (Php 500,000) in
form of moral damages and attorneys fees.

That I am executing this affidavit in order to attest to all the
foregoing facts and for the purpose of filing a criminal complaint for
violation of BP Blg. 22 against Sps. Ronnie & Bless Yu and, also for
Complainant to be paid of her claim for moral damages and attorneys
fees as aforementioned.

IN WITNESS WHEREOF, I have hereunto affixed my signature
this 16
th
of June, 2013 at Bacolod City, Philippines.



TILDA NAGA-UGTAS
Affiant


SUBSCRIBED AND SWORN to before me this 16
th
of June, 2013 at
Bacolod City, Philippines by the above-named affiant. I hereby certify
that I have personally examined the affiant and I am satisfied that she
has voluntarily executed and understood her affidavit.



JOSE MARIA CARPIO
2
nd
Assistant City Fiscal
Bacolod City