Republic of the Philippines)

Province of Cagayan ) S.S

Tuguegarao City )

COMPLAINT-AFFIDAVIT

That I, Evangeline P. Pascual, of legal age, Filipino, married and a

resident of Sunshine Valley Homes, Atulayan, Tuguegarao City, and after
having been duly sworn to in accordance with law do hereby depose and
say;

1. That sometime on September 2017, one CRISTINA TERMULO

DOTOR of legal age, Filipino and a resident of Jasmin st., Lillesville,
subdivision, Lawa, Meycauayan Bulacan approached me to borrow a
sum of money.

2. That said CRISTINA, offered a document purportedly an Original

Certificate of Title over a parcel of land as collateral for any amount
loan I might extend to him.

“A copy of the purported Original Certificate of Title is hereto attached

as Annex “A” and shall form as integral part hereof.”

3. That believing that the above-mentioned document is authentic; I

extended to him a loan in the amount of ONE HUNDRED
THOUSAND PESOS (P100,000) to be paid after twelve months (12)
from the execution of the Loan Agreement and with a monthly interest
of ten percent (10%).

“A copy of the Loan Agreement dated September 2017 is hereto

attached as Annex “B” and shall form as integral part hereof.”

4. That on November 16, 2017, the same CRISTINA DOTOR

approached me and borrowed additional sum of money amounting to
FIFTY THOUSAND PESOS (P50,000) secured by the same
Certificate of Title as collateral. Again, on my belief that the said
Original Certificate of Title is authentic, I readily lent him the said
amount of money.

“A copy of the Loan Agreement dated November 16, 2017 is hereto

attached as Annex “C” and shall form as integral part hereof.”

5. That after both loans have become due, I verbally demanded

payment from CRISTINA DOTOR but he failed to pay the same.

6. That on ________________, I learned that CRISTINA DOTOR

already left her house in Meycauayan Bulacan and could no longer
be found.
7. That upon verification with the Land Registration Authority, I found
out that the Certificate of Title of a parcel of land delivered to me by
said CRISTINA DOTOR as collateral for her loans is not genuine and
the Title No. indicated on the said document does not exist.

“A copy of the Information Request Form from the Land Registration

Authority is hereto attached as Annex “D” and shall form as integral
part hereof.”

8. That CRISTINA DOTOR, by means of false manifestations which he

made to me to the effect that he is mortgaging a parcel of land for
the total loan amount of ONE HUNDRED FIFTY THOUSAND PESOS
(150,000.00) and by means of other similar deceits induced and
succeeded in inducing me to give and deliver, as in fact I gave and
delivered to said CRISTINA DOTOR the amount of ONE HUNDRED
FIFTY THOUSAND PESOS (150,000.00) on the strength of said
manifestations and representations, said CRISTINA DOTOR well
knowing that the same were false and fraudulent, as the Certificate of
Title delivered to me is fake and not existing, and were made solely,
to obtain, as in fact he did obtain the amount of ONE HUNDRED
FIFTY THOUSAND PESOS (150,000.00) which amount once in his
possession, with intent to defraud, willfully, unlawfully and feloniously
misappropriated, misapplied and converted to his own personal use
and benefit, to my damage and prejudice in the aforesaid amount of
ONE HUNDRED FIFTY THOUSAND PESOS (150,000.00).

9. That I filed a complaint in the Office of the Punong Barangay of

_____________________________ against CRISTINA DOTOR on
________________.

“A copy of the Complaint dated July 25 2019 is hereto attached as

Annex “E” and shall form as integral part hereof.”

10. That the Office of the Lupong Tagapamayapa of Barangay

_________________, issued __________________ for the filing of
appropriate case against Joseph P. Iringan.

“A copy of Endorsement Letter/Certificate to File Action dated

_______________ is hereto attached as Annex “F” and shall form as
integral part hereof.”

11. Thus, with all the foregoing, I am executing this complaint-affidavit

to formally charge “CRISTINA DOTOR” with “ESTAFA” defined and
penalized under Article 315 (2) (a) of the Revised Penal Code of the
Philippines to wit;
 “Any person shall be liable for Estafa by using a fictitious name or
falsely pretending to possess power, influence, qualification, property,
credit, agency, or imaginary transactions or by means of similar
deceit.”

12. I am further executing this affidavit to attest the truthfulness of the

foregoing facts.

Further affiant sayeth naught.

IN WITNESS WHEREOF, I have hereunto set my hand this

____________________ in ________________________.

________________________________
Complainant/Affiant

SUBSCRIBED AND SWORN TO, before me this

___________________ in __________________________.

Doc. No. :____;

Page No. :____;
Book No. :____;
Series of: 2019.