Republic of the Philippines

Office of the City Prosecutor

Quezon City

LEONORA JUAREZ,
Complainant, Criminal Case
For: Estafa

-versus-

FERDINAND MANES,

Respondent,

x-----------------------------------------x

COMPLAINT

The Plaintiff, by counsel to this honorable Office, respectfully states that;

1. The Complainant is a Filipino, of legal age, married and a resident of 45

Marytown Circle, Greenfields 1, Kaligayahan, Novaliches Quezon City where she
may be served notices and other court processes;

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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.

4. The Complainant, after a month of the signing of the contract, has

discovered that the said property was already auctioned by the Quezon City
government for gross tax delinquency;

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.

7. WHEREFORE, premises considered, Complainant prays to this Honorable

Court that judgement be rendered in her favor;

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

ATTY. LUIS SANTOS

Counsel for the Plaintiff
PTR No. ____
IBP No. ____
Roll No. ___
Santos-Angeles Law Office
5 Marytown Circle, Greenfields 1,
Kaligayahan, Novaliches Quezon City

VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING

I, LEONORA JUAREZ, of Legal age, married, Filipino Citizen and a resident of

45 Marytown circle, Greenfields 1, Kaligayahan Novaliches, Quezon City, after
being sworn according to law, hereby depose and state that;

1. I am the complainant in the above-stated case;

2. I caused the preparation of the foregoing complaint;

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;

5. To the best of my knowledge and belief, no such action or proceeding is pending

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