Republic of the Philippines

Department of Justice
National Prosecution Office
Office of the City Prosecutor
Quezon City, Philippines

People of the Philippines, CRIMINAL CASE N0.______

Plaintiff, For: FALCIFICATION OF
PUBLIC DOCUMENT

-versus - 

KARDO DALISAY.
Accused.

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

COMPLAINT

Complainant Don Emilio Alawi, of legal age, married, Filipino and a

resident of 78 Fortune Village Batasan Hills, Quezon City, and within the
jurisdiction this Honorable Office accuses Kardo Dalisay of the crime of
Falsification of Public Document under the Revised Penal Code. The
circumstances leading to the filing of this complaint are as follows:
 Article 172. Falsification by private individuals and use
of falsified documents. - The penalty of prision correccional in
its medium and maximum periods and a fine of not more than
5,000 pesos shall be imposed.

The elements of the crime of falsification of private document

(Art. 172 (2)) are:1.That the offender committed any of the acts
of falsification, except those in paragraph 7,enumerated in Art.
171; 2.That the falsification was committed in any private
document; 3.That the falsification caused damage to a third
party or at least the falsification was committed with intent to
cause such damage.

Antecedent

1. I am the owner of a Lykan Hypersport by W Motors with plate no AAA

8888, which was previously been involved into a car accident causing
its tail light broken and tailgate trunk lids dented.

2. On January 7, 2019, I engaged with the services of Kardo Dalisay,

the mechanic and owner of Vendetta Motor Shop located at Banawe,
Quezon City for repair of aforementioned vehicle.

3. At the time the vehicle was delivered to Vendetta Motor Shop, it was
still in good running condition and serviceable because the under
chassis was not affected and the motor engine, wheels, steering
wheels and other parts were still functioning.
 4. As security and in exchange of the vehicle, Kardo Dalisay gave me a
photo copy of his own BIR Tin Identification and the Motor shop’s BIR
Certificate of Registration.

5. After reasonable time had elapsed, no repairs were made on the said
vehicle.

6. On February 14, 2019, I instructed my helper/driver, Homer Alakdan

to retrieve the vehicle but he was not able to find the motor shop. The
previous motor shop location was now vacated and clean.

7. Upon checking with the Bureau of Internal Revenue, the submitted

documents by Kardo Dalisay are all fake.

Attached to this complaint is the affidavit of witness – Homer Alakdan,

as Exhibit A and Kardo Dalisay’s submitted falsified documents, as Exhibit
B and C.

Contrary to law.

Don Emilio Alawi

Complainant
 SUBSCRIBED AND SWORN to before me this 20 th day of February,
2019, at City of Quezon, Philippines.

The undersigned Prosecutor certifies that he personally examined the

complainant and that he is satisfied that he voluntary executed and
understood his complaint.

Alyana Borja

Senior Assistant City Prosecutor

 VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, DON EMILIO ALAWI, of legal age, after having been duly sworn in
accordance with law, depose and state that:

1. I am a 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;
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.

Don Emilio Alawi

Affiant
 SUBSCRIBED AND SWORN to before me this 14 th of February
2019 at Quezon City affiant exhibiting to me his PRC ID No. 246810 issued
on 22nd of October 2010 at City of Manila.

Doc. No. ;
Page No. ;
Book No. ;
Series of 2019.