REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
QUEZON CITY
DRAGON MEGALINE CONCEPTS INC.,
Represented by: RONALD TAN
Complainant
-versus-

I.S NO:_________________
For: Estafa and B.P 22

MARY LEN MEDINILLA

Respondent.
X- - - - - - - - - - - - - - - - - - - - - - - - - - - -X
COMPLAINT- AFFIDAVIT
I, RONALD TAN, of legal age, Filipino Citizen
and with address at No. 93 Dapitan Extension
Sta. Mesa Heights, Quezon City, after being
sworn to in accordance with law hereby depose
and state;
1. That I am the duly authorize representative of
the complainant DRAGON MEGALINE
CONCEPTS, INC., to file, testify in the hearing
Mediation, Pre-trial and or Trial of Criminal
Case for Estafa and B. P 22 against MARY LEN
MEDINILLA with business address at ALPHA
CYCLE CENTER Enriquez St. Brarangay IV
Lucena City. as evidence with Special Power of
Attorney and Secretarys Certificate attached
as Annex
A and B;
2. That Complainant DRAGON MEGALINE
CONCEPTS INC, a corporation duly organized

and existing under the laws of the Republic of

the Philippines with principal address at No. 93
Dapitan Extension Sta Mesa heights, Quezon
City;
3. That sometime
on the month of March 2015 the respondent
purchased and obtained from the complainant
the unpaid assorted bicycle which you
purchased and obtained from the complainant
and issued post dated checks as payment of
the unpaid assorted bicycle which you
purchased from the complainant;
4. That the purchased ordered and obtained
bicycle by the respondent from the
complainant in the total amount of FOUR
HUNDRED TWENTY SEVEN THOUSAND SEVEN
HUNDRED PESOS (PHP. 427,700.00) and in
payment of the said purchased order bicycle,
the respondent simultaneously issued unto the
complainant corporation the following checks
to wit:
DATE
AMOUNT

BANK

July 11, 2015

BPI
Php. 44,400.00
July 21, 2015
BPI
Php. 24,600.00
July 31, 2015
BPI
Php. 31,200.00
August 4, 2015 BPI
Php. 42,000.00
August 12, 2015
BPI
Php. 30,800.00

CHECKS NO.
0000880843
0000880844
0000880845
0000880846
0000880847

August 19, 2015

BPI
Php. 21,600.00
August 26, 2015
BPI
Php. 29,000.00
August 26, 2015
AUB
Php. 44,400.00
September 2, 2015
BPI
Php. 22,800.00
September 9, 2015
BPI
Php. 15,600.00
September 10, 2015
AUB
Php. 24,600.00
September 20, 2015
AUB
Php. 31,200.00
September 23, 2015
BPI
Php. 25, 200.00
Sepetember 28, 2015
AUB
Php. 42,000.00
September 29, 2015
BPI
Php. 22,800.00
October 10, 2015
AUB
Php.30,800.00
October 20, 2015
AUB
Php. 21,600.00
October 30, 2015
AUB
Php. 29,000.00
November 10, 2015
AUB
Php. 22,800.00
November 12, 2015
RCBC
Php. 7,600.00
November 19, 2015
RCBC
Php.29,000.00
November 20, 2015
AUB
Php. 15,600.00
November 26, 2015
RCBC
Php. 16,800.00
November 30, 2015
AUB
Php. 25,200.00
December 3, 2015
RCBC
Php. 25,000.00
December 10, 2015
AUB
Php. 7,600.00
December 10, 2015
RCBC
Php. 25,000.00
December 17, 2015
RCBC
Php. 14,300.00

0000880848
0000880849
0001041822
0000880850
0000880851
0001041823
0001041824
0000880852
0001041825
0000880853
0001041826
0001041827
0001041828
0001041829
9000015
9000016
00001041830
9000017
0001041831
9000018
0001041832
9000019
9000020

Photocopy of the afore-mentioned checks are

hereto attached as Annexes C to C-16,
made an integral part of this complaintaffidavit.
5. The checks were issued on the months of
March, April, May and June 2015 to the office
of the complainant and it was deposited
every maturity date of the checks at the
drawee bank Estwest Bank Del Monte Branch
Quezon City, but eventually dishonored by
the drawee bank for the reason of ACCOUNT
CLOSED;
6. Respondent repeatedly, firmly and
persistently assured complainant that the
checks were good, properly and sufficiently
funded and that the bank will honor the
checks upon presentment for honor and
payment, only to find out, when the checks
were deposited with the bank for honor and
payment, the same were dishonored for the
reason of ACCOUNT CLOSED;
7. The subject checks were issued by means
deceit and false pretenses, the respondent
assuring complainant that the subject
checks were good, properly and sufficiently
funded and that the bank will honor and pay
the checks upon presentment for honor and
payment and were it not for these repeated,
firm and persistent assurances of the
respondent, complainant would not have
accepted the checks and parted with gift

checks purchased and obtained by

respondent;
8. Repeated and relentless demands were
made unto respondent to pay her obligation
or the cash value of the subject checks in the
total amount FOUR HUNDRED TWENTY
SEVEN THOUSAND SEVEN HUNDRED PESOS
(427,700.00), but said demands fell to deaf
ears since respondent ignored the demands
and up to present time persistently
continues to refuse and fails to pay her
obligation or the cash value of the subject
checks;
9. On September 29, 2015, October 7 & 14,
2015, Complainant, through Counsel sent
unto the respondent Notice of Dishonor and
Demand to Pay dated October 1, 7 and 14,
2015 for respondent to pay her obligation or
the cash value of the subject checks,
however, respondent remains heedless and
adamant and up to the present time
persistently continues to refuse and fails to
pay her obligation or the cash value of the
subject checks. Photocopies of the Letters of
Demand and Notice of Dishonored are hereto
attached as Annexes D to D-2 are made
indispensable parts of this ComplaintAffidavit;

10. Likewise attached hereto is an Affidavit of

Mailing as Annex E;
11.

Respondent issued the subject checks by

means of deceit, misrepresentation and false

pretenses to the damage and prejudice of
the complaint;
12. That I execute this Complaint- Affidavit to
attest to the truth of the foregoing facts and
for the purpose of filing a criminal complaint
for Violation of B.P Blg. 22 for the
respondent,
IN WITNESS WHEREOF, I have hereunto
affixed

my

signature

this

_____

day

of

_______________ 2016 at Quezon City, Philippines.

RONALD TAN
Affiant

SUBSCRIBED AND SWORN to before me this ___ day of

_____________, 2016 at Quezon City and I hereby certify that I have
personally examined the Affiant and that I am satisfied that she voluntarily
executed and understood her Complaint-Affidavit.

ASSISTANT CITY
PROSECUTOR

ANNEX

REPUBLIC OF THE PHILIPPINES )

E
CITY OF MANILA
X----------------------------------X

) S.S.

AFFIDAVIT OF MAILING
I, LITO V. PARAIRO, of legal age, Filipino and with office
addresses at 307 CCI Bldg., 1091 Concepcion Street, Ermita
Manila, under oath depose and state;
1. Atty. Leopoldo P. Dela Rosa is the Private Counsel of the
Complainant, in the Criminal of ESTAFA and Violation of
B.P. 22 case against:
Ms. MARY LEN MEDENILLA
ALPHA CYCLE CENTER
ENRIQUEZ ST. BRGY. IV
LUCENA CITY
2. I am employed with the office of Atty. Leopoldo P. Dela Rosa
as Clerk/Messenger;
3. I sent, via registered mail, a Letter of Demand to pay
Notice of Dishonor dated September 29, 2015 October 7
and 14, 2015 with Registry Receipts No. 25635,25642 and
25896, dated by the Post Office October 1,7 and 14 , 2015

the said letter was served personally to the respondent and

same it was received personally by the respondent;
4. That the said formal written letter of Demand to Pay and
Notice was served by herein affiant at KollectAgad Postal
Station Ermita Manila with Registry Nos. 25635,25642 and
25896 dated October 1,7 and 14, 2015 send to the
respondent;
IN WITNESS WHEREOF, I hereunto set my hand this _____
day of______, 2016 at the City of Manila for Quezon City,
Philippines.

ARNEL

CIMENE

Affiant
SUBSCRIBED AND SWORN to before me this _____day
of______________2016 at the City of Manila, Philippines.
Doc No:_______
Page No:______
Book No:______

Series of 201

NOTARY PUBLIC