Republic of the Philippines )

Metro Manila )S.S.

Quezon City )
x---------------x

COMPLAINT-AFFIDAVIT

I, Juan Miguel Abundo, of legal age, Filipino, single, and a resident of

Park-7, Loyola Heights, Quezon City, after having been duly sworn to in
accordance with law, hereby depose and state:

1. That I am initiating this complaint-affidavit against Genevieve Dela

Cruz for the violation of BATAS PAMBANSA BLG. 22 or “The
Bouncing Checks Law.” She is currently residing in Park-7, Loyola
Heights, Quezon City, where she can be served with notices and
summons.

2. That on the morning of October 15, 2018, at around 11:00 AM,

Genevieve Dela Cruz borrowed money from me in the amount of
SEVENTY THOUSAND PESOS (P 70,000.00), promising to pay within
three months;

3. That after more than a year, and after repeated demands for the return
of the borrowed money, on November 9, 2019, Genevieve Dela Cruz
finally issued to me a post-dated BANCO DE ORO CHECK dated
November 19, 2019, amounting to SEVENTY THOUSAND PESOS
(P 70,000.00), representing her payment for the borrowed money;
 4. That when the check was negotiated/presented for payment to the
drawee bank, BDO, Katipunan Branch, with business address at
Katipunan Ave, Loyola Heights, Quezon City, on the specified date
therein, it was returned unpaid for the reason that it was “DRAWN
AGAINST INSUFFICIENT FUNDS”, as seen in the attached ANNEX
A herein;

5. Demand letters, herein attached as ANNEX B, were sent to Genevieve

Dela Cruz by my counsel, for the former to rectify the situation.

6. However, as of date, she still refuses to do the same without reason;

7. Genevieve Dela Cruz violated BATAS PAMBANSA BLG. 22 by issuing

a check to apply for account or for value, with that check being
dishonored by the drawee bank for the reason of insufficient funds.

8. Therefore, I am executing this Complaint-Affidavit in support of the

charges for violation of BATAS PAMBANSA BLG. 22 against
Genevieve Dela Cruz, who may be served with subpoena and other
processes of this Honorable Court at his last known address at Park-
7, Loyola Heights, Quezon City.

IN WITNESS WHEREOF, I have hereunto affixed my signature this January

30, 2020 in Quezon City, Philippines

Juan Miguel Abundo

Affiant
 SUBSCRIBED AND SWORN TO before me this January 30, 2020 in
Quezon City, Philippines. I HEREBY CERTIFY that I have personally
examined the affiant and that I am fully satisfied that she voluntarily
executed and understood the same.

ATTY. ELMER A. GONZALES

Notary Public
Until December 31, 2020
Roll of Attorney 74322
IBP No. 1376 June 23, 1996
PTR No. 17656
Issued in Quezon City
On January 30, 2020