Republic of the Philippines

Department of Justice
OFFICE OF THE CITY PROSECUTOR
Baguio City

NAGOYA DEL MUNDO

Complainant , I.S. No.______________

-versus- For:

NALINLANG KHA VIOLATION OF B.P. 22

Respondent .
x-----------------------------------x

COMPLAINT AFFIDAVIT

I, NAGOYA DEL MUNDO , Filipino, of legal age,single and a resident

of No. 90 Kalye Pogi, Pacdal, Baguio City, Philippines , hereby state under oath that:

1. That I am filing a complaint against NALINLANG KHA who is of legal age,

single, Filipino Citizen and a resident of No. 123 Kagandahan street, Pacdal,
Baguio City, Philippines where she may be served summons and other process
of the Honorable Office.

2. Sometime in March 2015 I attended an inspirational talk on “making your

money grow” with other individuals in a hotel conference room in Baguio
City. I was invited to the gathering by some investors who shared glowing
stories of the profits they earned in a few short months after they invested their
money.

3. Mr. Estafador Pow gave the inspirational talk and introduced his company he
called Mysterio Investment Firm. He also introduced one of his staff, Mr.
Nalinlang Kha.
4. During the gathering, Mr. Estafador proposed to the attendees a very lucrative
business opportunity and he promised a thirty percent profit per month on
their investment. There was a lot of good vibes and positive testimony from
other investors during the meeting so all the attendees, Including me who
decided to invest my money with Mr. Estafador.

5. Initially, I invested P 500,000. After I received the promised pay outs, I added
to my previous capital another P 500,000 so that my total investment reached
P 1,000,000.

6. After a few months, I demanded the return of my total investment because I

had to fund my ukay-ukay business. I received amounts in the form of checks
issued by Mr. Estafador.

7. For reasons unknown, Mr. Estafador instructed me to return the checks. The
checks with Mr. Estafador’s signatures were replaced by checks signed by his
staff Mr. Nalinlang. The checks are BPI checks with the following dates and
amounts:

BPI Check no. 08093 July 15, 2016 P 250,000 (Annex “A”)
BPI Check no. 08094 August 15, 2016 P 250,000 (Annex “B”)
BPI Check no. 08095 September 15, 2016 P 250,000 (Annex “C”)
BPI Check no. 08096 October 15, 2016 P 250,000 (Annex “D”)

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TOTAL: P1 000 000

8. I deposited the checks with my bank BDO SM branch ten days after the date
indicated in each check but the checks were all successively dishonored
when sent to BPI and returned to BDO with the following stamp “CLOSED
ACCOUNT”.

9. I made several verbal demands upon Mr. Estafador and Mr. Nalinlang but
they both kept promising that their Chinese counterparts will most assuredly
remit the profits from Hongkong but it’s taking sometime due to our strict
bank regulations here in the Philippines.
 10.Fed up with the promises, I, through a notice of dishonour with demand
dated April 10, 2016 informed Mr. Estafador and Mr. Nalinlang of the
dishonor of the checks and demanded from them to make good the said
checks within FIVE banking days from receipt of the notice. The notice was
sent to the Mysterio Offices by registered mail with registry receipt signed
by a staff in the office. Mr. Estafador who already left for China and could not
be found.

11.Herein attached is the notice of dishonour with demand delivered by

registered mail with registry receipt signed by a staff in the office. Mr.
Estafador marked as (ANNEX “E”).

IN WITNESS WHEREOF, I have affixed my signature this 8th day of May

2019 in the City of Baguio, Philippines.

NAGOYA DEL MUNDO

Affiant

SUBSCRIBED AND SWORN to before me 8th day of May 2019

in the City of Baguio, Philippines. I FURTHER CERTIFY that I have personally
examined the Affiant and I am satisfied that he have read, understood and voluntarily
executed the foregoing affidavit-complaint.

Karingadaadan------- . .
Assistant City Prosecutor