REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Mandaluyong City, Branch No. 23

Brainy Kids Montessori

represented by Min A. Chin, President/ Owner
Plaintiff,

- versus - Civil Case No. 31

For: Collection of Sum
of Money

Security Bank – Kalentong Branch,

Defendant.

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

AFFIDAVIT

I, MAKASAIR A. ALVAREZ, of legal age, Filipino, and a resident of

209 New Era St., Mandaluyong City, after having duly sworn to in
accordance with law, hereby depose and say that:

1. I am an auditor from LBCC Auditing firm, the External Auditor of

Brainy Kids Montessori (hereafter referred to as “Montessori”), a school
owned by its sole proprietor Ms. Min A. Chin (hereafter referred to as
“plaintiff”) with principal address at 341 Kalentong St., Mandaluyong City;

2. As the External Auditor, I audit and examine the financial records,

and investigate to determine objectively if the financial statements
submitted for audit had been prepared in accordance with the appropriate
financial reporting standards. In addition, I ensure that the financial records
are accurate and that taxes are paid properly and on time;

3. In the course of the performance of my duties, functions and

responsibilities as the External Auditor of the Montessori, specifically in the
second (2nd) quarter of this year, I came to know that nine (9) of the
plaintiff’s checks under its Current Account No. 0291-0081-01 issued by
Security Bank – Kalentong Branch (hereafter referred to as “defendant”)
were stolen and encashed by a certain Magna Nacao since 2015 in the total
amount of Seven Hundred Eighty Two Thousand Pesos (Php782,600.00).

A copy of the checks forged by Magna Nacao is hereto attached and

made an integral part hereof, as follows:

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 Check No. 839700 dated April 24, 2015 with total amount in the sum
of P43,400.00 marked as exhibit “C”.

Check No. 839459 dated November 2, 2015 with total amount in the
sum of P110,500.00 marked as exhibit “C-1”.

Check No. 8397609 dated October 17, 2016 with total amount in the
sum of P47,723.00 marked as exhibit “C-2”.

Check No. 839549 dated April 7, 2016 with total amount in the sum of
P90,700.00 marked as exhibit “C-3”.

Check No. 839569 dated September 23, 2016 with total amount in the
sum of P52,27.00 marked as exhibit “C-4”.

Check No. 729149 dated March 22, 2017 with total amount in the sum
of P148,000.00 marked as exhibit “C-5”.

Check No. 729129 dated March 16, 2017 with total amount in the sum
of P51,015 marked as exhibit “C-6”.

Check No. 839684 dated December 1, 2017 with total amount in the
sum of P140,000.00 marked as exhibit “C-7”.

Check No. 729034 dated March 22, 2018 with total amount in the sum
of P98,985.00 marked as exhibit “C-8”.

4. In view of the above-stated incident, Respondent Bank encashed the

aforesaid checks upon presentment for payment and debited the account of
the plaintiff;

5. As a consequence thereof, plaintiff engaged the services of its

counsel, Atty. Jennifer A. Lopez for which the plaintiff agreed to pay One
Hundred Thousand Pesos (Php100,000.00) by way of attorney’s fees for the
purpose of enforcing her claim against the defendant; and

6. Thus, the plaintiff through the above-mentioned counsel filed

complaint against Security Bank and docketed as Civil Case No. 31 for
Collection of Sum of Money, which is pending before Regional Trial Court
in Mandaluyong City, Branch 23.

IN WITNESS WHEREOF, I have hereunto set my hand this _______

day of _______ 2018 at Mandaluyong City.

MAKASAIR A. ALVAREZ
Affiant

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 SUBSCRIBED AND SWORN to before me, a Notary Public for and in
Mandaluyong City, this ____ day of __________ 2018, affiant exhibited to
me his Comm. Certificate No. 0125536 issued at Mandaluyong City on March
9, 2017.

Notary Public

Doc. No.
Page No.
Book No.
series of 2018

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