REPUBLIC OF THE PHILIPPINES

OFFICE OF THE CITY PROSECUTOR

GENERAL SANTOS CITY

AVENGERS CORPORATION
represented by THOR ODINSON
I.S. No.__________________
Complainant, FOR: Violation of Article 315 of
the Revised Penal Code and B.P.
- versus - Blg. 22

BRUCE BANNER
Respondent.
x-------------------x

COMPLAINT-AFFIDAVIT

I, THOR ODINSON, of legal age, Filipino with address at Block 21,

Lot 5, Sarangani Homes Subd. Phase 1, Brgy. San Isidro, General Santos
City, representing AVENGERS CORPORATION, under oath, deposes and
says:

I respectfully file this Complaint-Affidavit against BRUCE BANNER

who is a Filipino, of legal age with address at Purok 18, Nursery Road,
Brgy. Lagao, General Santos City, for Swindling under Article 315 of the
Revised Penal Code and violation of Batas Pambansa Bilang 22 as narrated
herein below.

1. I am the owner of the AVENGERS CORPORATION (herein

referred to as the “AVENGERS” for brevity).

2. I started my business, AVENGERS CORPORATION since

2010.

3. The AVENGERS is an aquaculture company that sells milkfish,

tilapia, prawns, seabass, pomfret and processed milkfish products.

4. BRUCE is a customer of the AVENGERS to whom the latter

sells and supplies aquaculture products upon order.

Complaint-Affidavit of Thor Odinson; 1

 5. On July 16, 2019, BRUCE ordered Vannamei Shrimps from the
AVENGERS in the total amount of One Hundred Thousand Pesos (PhP100,
000.00).
6. On the same day, BRUCE wrote in favor of the AVENGERS a
Post-Dated Check amounting to Fifty Thousand Pesos (PhP50, 000.00) in
partial payment of his order.

The said check is hereto attached as Annex “A” and is made

an integral part of this complaint affidavit.

7. Based on our contract, BRUCE shall pay 50% of the total

amount as down payment, and the remaining amount shall be paid in full
upon delivery by virtue of a Post-Dated Check.

The said contract is hereto attached as Annex “B” and is

made an integral part of this complaint affidavit.

8. Upon completion of the delivery on July 17, 2019, BRUCE

issued the AVENGERS a check in the amount of Fifty Thousand Pesos as
payment for his remaining obligation.

The said check is hereto attached as Annex “C” and is made

an integral part of this complaint affidavit.

9. These transactions can be proven by a Sales Invoice.

The said check is hereto attached as Annex “D” and is made

an integral part of this complaint affidavit.

10. When we deposited the two Post-Dated Checks to the RCBC

Savings Banks in Pioneer Avenue, General Santos City, the drawee bank
dishonoured the same for insufficiency of funds.

11. On July 23, 2019, I wrote a demand letter to BRUCE informing

him that the checks he issued were dishonored with a demand that he settles
his obligation within ten (10) days from receipt thereof; otherwise I will file
a case against her.

12. The said letter can be proven to be received by BRUCE himself

by her signature indicating the same

The said letter is hereto attached as Annex “C” and is made

an integral part of this complaint affidavit.

Complaint-Affidavit of Thor Odinson; 2

 13. However, until this date, BRUCE still failed to pay his
remaining obligations despite the receipt of my demand letter.

14. Based on the above-mentioned facts, I file this Complaint-

Affidavit against BRUCE BANNER for Swindling under Article 315 of the
Revised Penal Code and violation of Batas Pambansa Bilang 22, and/or for
any other crime or felony that may have been committed by the latter under
the foregoing facts.

IN WITNESS WHEREOF, I hereunto set my hand this

_____________, at General Santos City, Philippines.

THOR ODINSON
Affiant
Valid ID. L04-11-1818181

SUBSCRIBED AND SWORN to before me this ______________ at

General Santos City, Philippines; I certify that I have personally examined
the herein Affiant and I am satisfied and convinced that he voluntarily
executed and understood his affidavit.

Doc. No. _____; NOTARY PUBLIC

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

Complaint-Affidavit of Thor Odinson; 3

Complaint-Affidavit of Thor Odinson; 4