Republic of the Philippines

Metropolitan Trial Court

Quezon City- Branch

PURE DIGITAL CONCEPT

represented by ANITA DIAZ
Complainant,
CIVIL CASE NO.
FOR: Collection of Sum of
Money
-versus-

CABALEN CORPORATION
represented by Maritel Nievera
& Sally Oiga
Respondents,
x - - - - - - - - - - - - - - - - - - - - - - - - - - - - -x
AFFIDAVIT OF ANITA DIAZ
I, ANITA M. DIAZ, Filipino, of legal age, with office address at 107
West Avenue, Quezon City 1105, after having been sworn in accordance
with law, hereby depose and state that:

1. I am the secretary of complainant PURE DIGITAL CONCEPT, a

partnership duly organized and existing under the laws of the
Philippines, with business and postal address at 107 West Avenue,
Quezon City 1105. I have been authorized to file the instant civil case
as shown in the Special Power of Attorney herein attached as “Annex
A”

2. Complainant PURE DIGITAL CONCEPT is engaged in the

business of SALE OF HOME THEATER EQUIPMENT &
SERVICE CENTER;

3. Respondent CABALEN CORPORATION is a domestic corporation

duly organized and existing under the laws of the Philippines, with
business and postal address at 54 JP Rizal St., Project 4, Quezon City
1109, represented by Maritel Nievera and Sally Oiga;

4. As a sectary of PURE DIGITAL CONCEPT, one of my assigned

duties includes handling collections of various accounts of clients
which includes respondent.

5. That on the following dates specifically, October 24, 2019, February

6, 2020, February 14, 2020, and December 3, 2020 the complainant,
PURE DIGITAL CONCEPT sold and delivered speakers, DVD
player, and amplifier equipment to respondent covered by Sales
Invoice Nos.17003, 0283, 17303, 0341, 0342, 17659,1007, in the total
amount Php72,500.00. I attest and affirm under oath that the
foregoing sales invoices herein referred to as “Annex “A, B, C, D, E,
F, G,” are certified photocopies of the documents they purport to be.
 Page 2
Complaint-Affidavit
6. That after 30 Days specifically November 24, 2019, March 6, 2020,
March 14, 2020, and January 3, 2021 , complainant went to
respondent’s store to collect payment of the goods delivered;

7. That despite repeated demands, the respondent failed and refused and
still fails and refuses to comply with their obligation.

8. That the complainant sent collection letters dated September 10, 2021,
October 1, 2021, February 18, 2022, March 31, 2022 to the
respondent and was received by Ms. Fatima Salazar, Ms. Cecil Ibias,
and Ms. Luisa Casinillo (accounting department) on September
10,2021, October 1, 2021, February 22, 2022, April 1, 2022. A copy is
hereby attached as Annex “H, I, J, K”;

9. That several demand letters dated February 18,2022 (with registry

receipt #7980 dated February 24,2022) and May 24,2022 (with
registry receipt #5531 dated May 24,2022) were sent to the
Respondent via registered mail, but remain unacted;

10.That as of writing, respondent has not paid its obligation in the total
amount of Php72,500.00.

11.I am executing this Affidavit in order to attest to the truth of the

foregoing and in support of the civil case against respondent.

IN WITNESS WHEREOF, I have hereunto affixed my signature this

_______ of _______ 2022 at Quezon City

ANITA DIAZ
Complainant-Affiant

SUBSCRIBED AND SWORN TO before me in the City

of ____ on this day of _____________, 2022, affiant exhibiting before
me her government issued identification card
____________________________, bearing her recent photograph and
specimen signature issued on __________________ at
_____________________.

NOTARY PUBLIC

Doc. No. _______.

Page No. _______.
Book No. _______.
Series of 2022.