REPUBLIC OF THE 

PHILIPPINES
OFFICE OF THE CITY PROSECUTOR
CITY OF DASMARIÑAS
      
MR. RUBEN BARCELON VISTA
Respondent

COMPLAINT AFFIDAVIT

              I, Darylle S. Lenchico, Filipino, of legal age, with postal address at Block 5, Lot 24,
Georgetown Heights Subdvision, Molino 4, Bacoor, Cavite, after being duly sworn in to
accordance with law, hereby depose and say:

1. That I am employed as a Junior Legal Officer of EQGRANT LENDING CORP., a lending

company duly organized and existing under and by virtue of laws of the Philippines with
principal address at 3Roze Building, Governor’s Drive, Sampaloc 1, Dasmariñas City,
Cavite. `
2. That as Legal Officer of the company, my duties include, monitoring and collection of
delinquent accounts or past due accounts, delivery of demand letters and represent the
company in cases against delinquent borrowers of all the branches of the company.

3. That I am authorized by the company to file a criminal case for violation of Batas Pambansa
Bilang 22 against principal borrower Mr. Ruben Barcelon Vista who can be served with
summon at Blk. 17, Zinnia St., Seanette Garden 1, Pulang Lupa, Las Piñas City, Metro
Manila. Attached hereto as Annex “A” the Secretary Certificate authorizing me to
represent the company.

4. On 11 June 2018, principal borrower Mr. Ruben Barcelon Vista applied for a loan and was
granted by EQGRANT LENDING CORP.,-Dasmariñas City Branch in the amount of One
Hundred Fifty Thousand Pesos Only (Php150,000.00) with an interest of 4% per month
for six (6) months. Mr. Ruben Barcelon Vista executed a Promissory Note in the amount of
One Hundred Eighty Six Thousand Pesos (Php186,000.00). Copy of Promissory Note
is hereto attached as Annex “B”.

5. Simultaneous with obtaining the loan from the our company (Dasmariñas City Branch) Mr.
Ruben Barcelon Vista issued and delivered the post-dated checks as payment for his
amortization to EQGRANT LENDING CORP. - Dasmariñas City Branch located at 3Roze
Building, Governor’s Drive, Sampaloc 1, Dasmariñas City and within the jurisdiction of this
Honorable Office, Security Bank Kalentong, Mandaluyong Branch checks in payment of his
obligation covered by the Promissory Note.

The respondents issued a several checks and these initial TWO (2) among the several
checks are the subject of this case amounting to Php 31,000.00, to wit:

Security Bank - Kalentong, Mandaluyong Branch 5057680  Oct. 11, 2019 Php 15,500
   Security Bank - Kalentong, Mandaluyong Branch 5057681  Nov. 11, 2019 Php 15,500

6. When presented to our Chinabank - SM Dasmariñas City Branch, our company depository
bank were dishonored due to ACCOUNT CLOSED. Copies of the front and dorsal portions
of the checks are hereto attached as Annexes “C”,“D”.

7. Likewise, written and verbal demands through demand letters and collection follow up to
settle the obligation were made but Mr. Ruben Barcelon Vista refused and failed and
continues to refuse and fail to pay their just and valid obligation.
 8. As a result of the failure of Mr. Ruben Barcelon Vista, to make good of the checks, the
company was constrained to engage the services of a counsel wherein the bank paid and
amount of Php 20,000.00 plus Php 3,000.00 per appearance in the hearings.

9. Herein attached are the Demand Letters delivered to the residence of Mr. Ruben Barcelon
Vista through registered mail with return card on Oct. 28, 2019 and Nov. 14, 2019 as
ANNEX “E” and ANNEX “F” respectively.

10. I am executing this Affidavit to attest to the truthfulness of the foregoing and for the
purpose of charging Mr. Ruben Barcelon Vista, of two (2) counts of violation of Batas
Pambansa Blg. 22.

IN WITNESS WHEREOF, I have affixed my signature this _____ day of November

2019 in Dasmariñas City, Cavite, Philippines.
Darylle S. Lenchico
Affiant

SUBSCRIBED AND SWORN to before me this ______ day of February 2019 in

Dasmariñas City, Province of Cavite. I further certify that I have personally examined
the Affiant and I am satisfied that she voluntarily executed her Counter-Affidavit and
that she understood the contents of the same.

CITY PROSECUTOR

CERTIFICATION

This is to certify that I have personally examined the affiant and I am convinced that he
has fully executed this Complain-Affidavit, read the same and understood the contents
thereof and that the allegation therein are true and correct of his personal knowledge and
based on the authentic documents in his possession.

CITY PROSECUTOR