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LEONORA JUAREZ,
Complainant, Criminal Case
For: Estafa
-versus-
FERDINAND MANES,
Respondent,
x-----------------------------------------x
COMPLAINT
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2. The Accused is likewise a Filipino, of legal age, married and residing at 13
Pasong Putik, Quirino Hway, Novaliches Quezon City where he may be served
summons and other court processes;
3. The Complainantt and the Accused entered into a (a) Real Mortgage
agreement; the latter lending (b) Twenty Million Pesos (P 20,000,000.00) through
check for the (c) house and lot with TCT ___ as collateral of the former. Attached
are the three copies of the documents as annexes A, B,C.
5. The Accused has continued to ignore the demand letters to return the said
amount of the Plaintiff, both oral and written. Copies of Demand letters are
attached as Annex D;
6. Before filing of this complaint, the dispute has been referred to the Lupong
Tagamayapa of Brgy. Kaligayahan, Novaliches Quezon City but the parties failed
to arrive at an amicable settlement.
a. The Accused shall return the above mentioned amount plus interest;
b. The Accused shall pay moral and exemplary damages;
c. The Accused shall be ordered to pay P 500,000 for the Attorney’s Fees.
Such other reliefs and remedies under the premises are likewise prayed for.
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Quezon City, Philippines, this 30th day of July 2018.
Signed
3. I have read the contents thereof and the facts stated therein are true and correct
of my personal knowledge and/or on the basis of copies of documents and records
in my possession;
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4. I have not commenced any other action or proceeding involving the same issues
in the Supreme Court, the Court of Appeals, or any other tribunal or agency;
6. If I should thereafter learn that a similar action or proceeding has been filed or is
pending before the Supreme Court, the Court of Appeals, or any other tribunal or
agency, I undertake to report that fact within five (5) days therefrom to this
Honorable Court.
Signed
LEONORA JUAREZ
Complainant
Date:
Subscribed and Sworn to before me this 30th day of July 2018, affiants exhibiting
to me her Identification Card with her respective name.
Signed
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ATTY. LEONARDO MOJICA
Notary Public for Quezon City
PTR No. ____
Issued at ___
Date:
Doc. No. __
Page No.__
Book No. ___
Series of 2018