Republic of the Philippines

_____________________________)S.S

COMPLAINT – AFFIDAVIT

I, Jasmin Veniegas Co, of legal age, single, Filipino and

resident of Phase 10A Package 2 Block 17 Lot 1 Barangay 176,
Bagong Silang Caloocan City, by virtue of Special Power of
Attorney vested in (hereto attached as “Annex A”) me after having
been duly sworn to according to law hereby depose and say:

1. That I am the undersigned Authorized Representative for

and in behalf of ARRABEL QUEENIE VALENZUELA
(hereinafter “Complainant”) also a Filipino and resident of
No. 33 5th West Crame, Brgy. West Crame San Juan City.

2. In behalf of the Complainant, I am filing a formal complaint

for

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. 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, BODY
Kauswagan Branch, Cagayan de Oro City amounting to PhP
5,000,000.00.
 3. 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

4. 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 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a manager’s check issued by the bank and withdrawn by the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;

5. 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;

6. 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;

7. The unlawful acts by Respondent caused damage and

prejudice to South Bank in the amount of PhP 5,000,000.00,

1
Annex “A”.

2
Annex “B”

3
Annex “C”.
4 Annex “D”.
 the amount released to respondent as proceeds of the loan,
including interest of twelve percent (12%) per annum;

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

9. 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.

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, atATTESTATION
Cagayan deCLAUSE
Oro City.

Vincy
Jane A. Polinar
Affiant

NAME AND SIGNATURE

JUAT OF AFFIANT
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.

Azrifa A. Mamutuk
Associate Prosecution
Attorney II