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AFFIDAVIT OF LOSS KNOW ALL MEN BY THESE PRESENTS:

I, Juan C Dela Cruz, of legal age, Filipino, single, and a resident of 123 Guinhawa, Malolos,
Bulacan , after having been sworn in accordance with law, hereby deposes and states the following:

1. I am holder/owner/ or possessor of a driver’s license with number C10-2034-1234 issued at


LTO Guiguinto:

2. On July 27, 2020, my wallet was stolen by two unknown individuals;

2. I have recently discovered the said item is irretrievably lost and can no longer be found
despite diligent efforts to locate the same;

3. I execute this affidavit to attest to the truth of the foregoing.

Signed on the date and at the place indicated below.

Juan C Dela Cruz


Affiant

Competent Evidence of Identity ID:


Passport No. 1234-5678
Issued on: 05/10/2019
At: DFA Pasay

SUBSCRIBED and SWORN TO before me on the date and at the place indicated below. The affiant
exhibited to me his competent evidence of identity as indicated above. Signed this 29 th of July at
Malolos, Bulacan Philippines.

WITNESS MY HAND AND SEAL.

Atty. AAA B. Abcde


NOTARY PUBLIC
Hiraya Mayawari, Malolos, Bulacan
Until December 31, 2024
PTR No. 1234567/1-13-19/Pasay
IBP No. 7654321/1-23-19/Pasay
Roll No. 28761
MCLE Compliance No. IV-123/Pasay/01-12-19
Doc. No.
Page No.
Book No. I
Series of
AFFIDAVIT OF DAMAGE TO VEHICLE

I, Juan C Dela Cruz, of legal age, Filipino, single, and a resident of 123 Guinhawa, Malolos,
Bulacan , after having been sworn in accordance with law, hereby depose and state the following:

1. I am a duly licensed driver with Driver’s License No. C10-2034-1234 which is valid until
December 2024:

2. On July 27, 2020, at around 7 o’clock in the evening, I was driving a motor vehicle owned and
registered in my name, and is more particularly described as a Ford Ecosport, ACD1934, White, 2018
model;

2. As I was trying to park at a local supermarket’s parking area, I hit a post from behind;

2. Because of this, my car incurred damage on its right-side tail light;

2. There was no witness to this incident;

3. I execute this affidavit to attest to the truth of the foregoing.

Signed on the date and at the place indicated below.

Juan C Dela Cruz


Affiant

Competent Evidence of Identity ID:


Passport No. 1234-5678
Issued on: 05/10/2019
At: DFA Pasay

SUBSCRIBED and SWORN TO before me on the date and at the place indicated below. The
affiant exhibited to me his competent evidence of identity as indicated above. Signed this 29 th of July at
Malolos, Bulacan Philippines.

WITNESS MY HAND AND SEAL.

Atty. AAA B. Abcde


NOTARY PUBLIC
Hiraya Mayawari, Malolos, Bulacan
Until December 31, 2024
PTR No. 1234567/1-13-19/Pasay
IBP No. 7654321/1-23-19/Pasay
Roll No. 28761
MCLE Compliance No. IV-123/Pasay/01-12-19
Doc. No.
Page No.
Book No. I
DEED OF ABSOLUTE SALE

KNOW ALL MEN BY THESE PRESENTS:

This DEED OF ABSOLUTE SALE is made, executed and entered into by:

JUAN DELA CRUZ of legal age, single, Filipino, and with residence and postal address at 123
Guinhawa, Malolos, Bulacan, hereinafter referred to as the SELLER

-AND-

PEDRO SANTOS, of legal age, single, Filipino and with residence and postal address ABC
Guinhawa, Malolos, Bulacan, hereinafter referred to as the BUYER.

WITNESSETH;

WHEREAS, the SELLER is the registered owner of a parcel of land with improvements located at
MAUNLAD, MALOLOS, BULACAN and covered by Transfer Certificate of Title No. 0392019023414
containing a total area of TWO HUNDRED FIFTY (250) SQUARE METERS, more or less;

WHEREAS, the BUYER has offered to buy and the SELLER has agreed to sell the above mentioned
property for the amount of TEN MILLION PESOS (P 10, 000,000.00) Philippine Currency;

NOW THEREFORE, for and in consideration of the sum of TEN MILLION PESOS (P 10, 000,000.00)
Philippine Currency, hand paid by the vendee to the vendor, the SELLER DO HEREBY SELL, TRANSFER,
and CONVEY by way of Absolute Sale unto the said BUYER, his heirs and assigns, the certain parcel of
land together with all the improvements found thereon, free from all liens and encumbrances of
whatever nature including real estate taxes as of the date of this sale.

JUAN DELA CRUZ PEDRO SANTOS

SIGNED IN THE PRESENCE OF:

__________________________ ____________________________

ACKNOWLEDGMENT

BEFORE ME, a Notary Public for and in the City of ___________________, personally appeared:

Name CTC Number Date/Place Issued

JUAN DELA CRUZ 10000000 Jan 15, 20__ / Angeles City


PEDRO SANTOS 10000000 Jan 9, 20__ / Manila

Known to me and to me known to be the same persons who executed the foregoing instrument and
acknowledged to me that the same are their free act and voluntary deed. This instrument, consisting of
(__) pages, including the page on which this acknowledgment is written, has been signed on the left
margin of each and every page thereof by the concerned parties and their witnesses, and sealed with
my notarial seal.

WITNESS MY HAND AND SEAL on this 29th of July 2020, at Malolos, Bulacan, Philippines.

Atty. AAA B. Abcde


NOTARY PUBLIC
Hiraya Mayawari, Malolos, Bulacan
Until December 31, 2024
PTR No. 1234567/1-13-19/Pasay
IBP No. 7654321/1-23-19/Pasay
Roll No. 28761
MCLE Compliance No. IV-123/Pasay/01-12-19
Doc. No.
Page No.
Book No. I
SPECIAL POWER OF ATTORNEY

KNOW ALL MEN BY THESE PRESENTS:

I, JUAN DELA CRUZ of legal age, single, Filipino, and with residence and postal address at 123 Guinhawa,
Malolos, Bulacan, do hereby APPOINT SIMON CASTRO, of legal age, single, Filipino, and with residence
and postal address at ABC Guinhawa, Malolos, Bulacan, as my true and legal representative to act for
and in my name and stead and to perform the following acts:

To sell, offer for sale, and come to an agreement as to the purchase price and thereafter to sign for me
and in my name and receive payment from the sale of my property more particularly described as
follows:

The parcel of land with improvements located at MAUNLAD, MALOLOS, BULACAN and covered
by Transfer Certificate of Title No. 0392019023414 containing a total area of TWO HUNDRED FIFTY (250)
SQUARE METERS, more or less;

HEREBY GRANTING unto my representative full power and authority to execute and perform every act
necessary to render effective the power to sell the foregoing properties, as though I myself, have so
performed it, and HEREBY APPROVING ALL that he may do by virtue hereof with full right of substitution
of his person and revocation of this instrument.

IN WITNESS WHEREOF , WE HAVE HEREUNTO SET OUR HANDS THIS ____ DAY OF _______________
20__, AT (Insert Place of execution of this Instrument).

JUAN DELA CRUZ SIMON CASTRO

BEFORE ME, a Notary Public for and in the City of ___________________, personally appeared:

Name CTC Number Date/Place Issued

JUAN DELA CRUZ 10000000 Jan 15, 20__ / Angeles City


SIMON CASTRO 10000000 Jan 9, 20__ / Manila

Known to me and to me known to be the same persons who executed the foregoing instrument and
acknowledged to me that the same are their free act and voluntary deed. This instrument, consisting of
(__) pages, including the page on which this acknowledgment is written, has been signed on the left
margin of each and every page thereof by the concerned parties and their witnesses, and sealed with
my notarial seal.

WITNESS MY HAND AND SEAL on this 29th of July 2020, at Malolos, Bulacan, Philippines.

Atty. AAA B. Abcde


NOTARY PUBLIC
Hiraya Mayawari, Malolos, Bulacan
Until December 31, 2024
PTR No. 1234567/1-13-19/Pasay
IBP No. 7654321/1-23-19/Pasay
Roll No. 28761
MCLE Compliance No. IV-123/Pasay/01-12-19
Doc. No.
Page No.
Book No. I
SPECIAL POWER OF ATTORNEY

KNOW ALL MEN BY THESE PRESENTS:

I, JUAN DELA CRUZ of legal age, single, Filipino, and with residence and postal address at 123 Guinhawa,
Malolos, Bulacan, do hereby APPOINT SIMON CASTRO, of legal age, single, Filipino, and with residence
and postal address at ABC Guinhawa, Malolos, Bulacan, as my true and legal representative to act for
and in my name and stead and to perform the following acts:

To sell, offer for sale, and come to an agreement as to the purchase price and thereafter to sign for me
and in my name and receive payment from the sale of my property more particularly described as
follows:

The parcel of land with improvements located at MAUNLAD, MALOLOS, BULACAN and covered
by Transfer Certificate of Title No. 0392019023414 containing a total area of TWO HUNDRED FIFTY (250)
SQUARE METERS, more or less;

HEREBY GRANTING unto my representative full power and authority to execute and perform every act
necessary to render effective the power to sell the foregoing properties, as though I myself, have so
performed it, and HEREBY APPROVING ALL that he may do by virtue hereof with full right of substitution
of his person and revocation of this instrument.

IN WITNESS WHEREOF , WE HAVE HEREUNTO SET OUR HANDS THIS ____ DAY OF _______________
20__, AT (Insert Place of execution of this Instrument).

JUAN DELA CRUZ SIMON CASTRO

BEFORE ME, a Notary Public for and in the City of ___________________, personally appeared:

Name CTC Number Date/Place Issued

JUAN DELA CRUZ 10000000 Jan 15, 20__ / Angeles City


SIMON CASTRO 10000000 Jan 9, 20__ / Manila

Known to me and to me known to be the same persons who executed the foregoing instrument and
acknowledged to me that the same are their free act and voluntary deed. This instrument, consisting of
(__) pages, including the page on which this acknowledgment is written, has been signed on the left
margin of each and every page thereof by the concerned parties and their witnesses, and sealed with
my notarial seal.

WITNESS MY HAND AND SEAL on this 29th of July 2020, at Malolos, Bulacan, Philippines.

Atty. AAA B. Abcde


NOTARY PUBLIC
Hiraya Mayawari, Malolos, Bulacan
Until December 31, 2024
PTR No. 1234567/1-13-19/Pasay
IBP No. 7654321/1-23-19/Pasay
Roll No. 28761
MCLE Compliance No. IV-123/Pasay/01-12-19
Doc. No.
Page No.
Book No. I
June 24, 2020

MR. PEDRO SANTOS


Unit 1, 20th Floor, ABC Building.
ABC Guinhawa, Malolos, Bulacan

Dear Mr. Santos:

My client, MR. JUAN DELA CRUZ, has referred to my office your outstanding obligation, pertaining to a
post-dated check amounting to 1 Million Peso that has been dishonored for the reason “Account
Closed”.

Banco de Oro Check No. 325396- P1,000,000.00

Despite several demands made to you by my client, however, you have refused to settle these past
due account to date.

In connection therewith, my client through my office is formally serving you this final demand to settle
your aforestated obligation plus 25% attorney’s fees within FIVE (5) days from receipt hereof.

Otherwise, much to my regret, my client shall have no other choice but to file his contemplated legal
action(s) against you in order to protect his best interests. On the other hand, my client prefers that you
settle this obligation extra-judicially with my office within the aforesaid period. Your preferential
attention on this matter will be deeply appreciated. Thank you.

Very truly yours,

ATTY. CHLOE ANNE SY GALITA


Counsel for Juan Dela Cruz

At My Instance:

JUAN DELA CRUZ


Client
REPUBLIC OF THE PHILIPPINES
OFFICE OF THE CITY PROSECUTOR CITY OF MALOLOS

JUAN DELA CRUZ


Complainant,
- versus - IS No.: ____________
For: Violation of B.P. Blg. 22

PEDRO SANTOS
Respondent. x---------------------------------x

COMPLAINT

I, JUAN DELACRUZ, JUAN DELA CRUZ of legal age, single, Filipino, and with residence and postal address
at 123 Guinhawa, Malolos, Bulacan, after being sworn to in accordance with law, depose and state that:
I know the person of PEDRO SANTOS, of legal age, single, Filipino, and with residence and postal address
at ABC Guinhawa, Malolos, Bulacan;

On the 20th of June 2020, I entered with said Pedro SANTOS a contract of sale, whereby he agrees to
purchase my vehicle unit Ford Mustang. A copy of said sale is hereby attached and marked as
ANNEX “A”;

For and in consideration of which, Pedro issued in my favor one (1) post-dated checks, Banco de Oro
Check No. 325396 in the amount of 1,000,000.00 as supposed payment for the aforementioned sale; A
true and faithful machine reproduction of the said checks are hereto attached as
ANNEX “B”;

The said checks are drawn against the account of the said Pedro Castro at BDO with Account No. 01-
12345678;

That at the time the said Pedro Santos issued the delivered the said check to me, he made the assurance
and representation that said checks are good checks and would be covered by sufficient funds when
presented for payment;

However, when the check was deposited, the same were dishonored and returned by the bank on the
ground that all were drawn against a "CLOSED ACCOUNT";

I immediately notified said Pedro Santos of the dishonor and return of the said checks and demanded
from him that he make good the said check within five days (5) days from receipt thereof. A true and
faithful machine reproduction of my Demand Letter to him dated
June 24th 2020 is hereto attached as ANNEX "C"

He repeatedly promised to make good the checks. I extended to him much leniency as I am also a very
busy man.
B.P. Blg. 22 (Bouncing Checks Law) provides:

Any person who makes or draws and issues any check to apply on account or for value, knowing at the
time of issue that he does not have sufficient funds in or credit with the drawee bank for the payment of
such check in full upon its presentment, which check is subsequently dishonored by the drawee bank for
insufficiency of funds or credit or would have been dishonored for the same reason had not the drawer,
without any valid reason, ordered the bank to stop payment, shall be punished by imprisonment of not
less than thirty days but not more than one (1) year or by fine of not less than but not more than double
the amount of the check which fine shall in no case exceed Two Hundred Thousand pesos, or both such
fine and imprisonment at the discretion of the court.

The same penalty shall be imposed upon any person who having sufficient funds in or credit with the
drawee bank when he makes or draws and issues a check, shall fail to keep sufficient funds or to
maintain a credit to cover the full amount of the check if presented within a period of ninety (90) days
from the date appearing thereon, for which reason it is dishonored by the drawee bank.

The making, drawing and issuance of a check payment of which is refused by the drawee because of
insufficient funds in or credit with such bank, when presented within ninety (90) days from the date of
the check, shall be prima facie evidence of knowledge of such insufficiency of funds or credit unless such
maker or drawer pays the holder thereof the amount due thereon, or makes arrangements for payment
in full by the drawee of such check within five (5) banking days after receiving notice that such check has
not been paid by the drawee.

It shall be the duty of the drawee of any check, when refusing to pay the same to the holder thereof
upon presentment, to cause to be written, printed or stamped in plain language thereon, or attached
thereto, the reason for drawee's dishonor or refusal to pay the same: Provided, That where there are no
sufficient funds in or credit with such drawee bank, such fact shall always be explicitly stated in the
notice of dishonor or refusal. In all prosecutions under this Act, the introduction in evidence of any
unpaid and dishonored check, having the drawee's refusal to pay stamped or written thereon, or
attached thereto, with the reason therefor as aforesaid, shall be prima facie evidence of the making or
issuance of said check, and the due presentment to the drawee for payment and the dishonor thereof,
and that the same was properly dishonored for the reason written, stamped or attached by the drawee
on such dishonored check.

Notwithstanding receipt of an order to stop payment, the drawee shall state in the notice that there
were no sufficient funds in or credit with such bank for the payment in full of such check, if such be the
fact."

Further, BP Blg. 22 enumerates the elements of the crime to be

(1) the making, drawing and issuance of any check to apply for account or for value;

(2) the knowledge of the maker, drawer, or issuer that at the time of issue he does not have
sufficient funds in or credit with the drawee bank for the payment of the check in full upon
its presentment; and
(3) the subsequent dishonor of the check by the drawee bank for insufficiency of funds or
credit or dishonor for the same reason had not the drawer, without any valid cause, ordered
the bank to stop payment.

PRAYER.

WHEREFORE, premises considered, it is respectfully prayed that after notice and hearing the respondent
be indicted VIOLATION OF B.P. BLG. 22 to protect/preserve the right/interest of the complainant to
recover his claim of ONE MILLION PESOS, plus exemplary damages of P100,000.00, moral damages of
P100,000.00, attorney’s fees of P125,000.00 plus 5% of the recoverable amounts, and costs of suit.

JUAN DELA CRUZ


Complainant
LTO Driver’s License No.
Expiring on

Assisted By:

ATTY. CHLOE ANNE SY GALITA


Counsel for Plaintiff

SUBSCRIBED and sworn to before in Malolos City me this 29th day of July 2020, affiant/complainant
showing his official identification document as stated above.

Administering Assistant City Prosecutor


REPUBLIC OF THE PHILIPPINES
OFFICE OF THE CITY PROSECUTOR CITY OF MALOLOS

JUAN DELA CRUZ


Complainant,
- versus - IS No.: ____________
For: Violation of B.P. Blg. 22

PEDRO SANTOS
Respondent. x---------------------------------x

/
*************************************************************************************
****/

INFORMATION
The undersigned Associate Prosecution Attorney II accuses Apipa G. Guro of the crime of
violation of the Bouncing Checks Law, committed as follows:

That on October 31, 2007 in the City of Cagayan de Oro, Philippines, and within the jurisdiction of the
Honorable Court, accused Apipa G. Guro [hereinafter “Accused”] misrepresenting herself to be Doña
Añiqa Macarambon-Bacsarpa, applied for a loan with South Bank in the amount of PhP 5,000,000.00. A
parcel of land located at Balulang, Cagayan de Oro City, covered by Certificate of Title No. T-178439, in
the name of Don Mario Bacsarpa married to Doña Añiqa Macarambon-Bacsarpa was then offered by the
accused as collateral. The accused did then and there wilfully, unlawfully, and feloniously falsify the
deed of real estate mortgage and the promissory note corresponding to the said loan by forging their
signatures when in truth and in fact they did not so participate, to the damage and prejudice of the
complaining bank and the Spouses Bacsarpas in the aforesaid sum of PhP 5,000,000.00.

Contrary to law.

Cagayan de Oro City, July 19, 2010

AZRIFA A. MAMUTUK
Associate Prosecution Attoryney II

Approved:
JOANNE N. VELEZ
City Prosecutor

BAILBOND REOCMMENDED: PHP 100,000.00


WITNESSES:

1. Vincy Jane A. Polinar – c/o South Bank, Kausawagan, Cagayan de Oro City
2. And others.

CERTIFICATION

This is to certify that as shown by the records the undersigned, an authorized officer, that there
is a reasonable ground to believe that a crime has been committed and that the accused is probably
guilty thereof; that the accused was informed of the complaint and of the evidence submitted against
her and was given an opportunity to submit controverting evidence.

AZRIFA A. MAMUTUK
Associate Prosecution Attorney II

SUBSCRIBED AND SWORN to before me this July 19, 2010 in the City of Cagayan de Oro,
Philippines.

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