Complaint BP22
Complaint BP22
COMPLAINT AFFIDAVIT
I, Meriam Acosta, Filipino, of legal age, married, and a resident of No. 1 Matapat St.,
cor. V.Luna Road, Diliman, Quezon City, after being sworn to in accordance with law,
depose and state:
That I know the person of Mercedes Santiago, who is a resident of No. 66 Maginhawa
St., Teachers Village, Quezon City;
That sometime in the morning of 19 June 2014, at Quezon City, Philippines, the said
Mercedes Santiago issued in my favor a BPI Check No. 123456789 in the amount of
One Million Pesos (PhP 1,000,000.00) as supposed payment for the loan
accommodation of One Million Pesos (PhP 1,000,000.00), which I have extended to
her;
That the said check is drawn against the account of the said Mercedes Santiago at BPI
with Account No. 987654321;
That at the time the said Mercedes Santiago issued the delivered the said check to me,
she made the assurance and representation that the said check is a good check and
would be covered by sufficient funds when presented for payment;
However, when the above-mentioned check was deposited, the same was dishonored
and returned by the bank on the ground that the same was drawn against a "CLOSED
ACCOUNT. A true and faithful machine reproduction of the said check is hereto
attached as Annex "A";
As such, I immediately notified said Mercedes Santiago of the dishonor and return of
the said check and demanded from her that she make good the said check within 15
days from receipt thereof. A true and faithful machine reproduction of my demand letter
to her is hereto attached as Annex "B";
When said Mercedes Santiago failed to heed my demands, I endorsed the said check to
my legal counsel who immediately sent a formal demand letter through registered mail
with return card on 19 September 2014, which was received by the said Mercedes
Santiago on 21 September 2014;
As of date however, Mercedes Santiago has unjustifiably ignored all these demands to
pay the said account and/or to redeem the said returned check. A true and faithful
machine reproduction of my demand letter to her is hereto attached as Annex C";
I am therefore executing this Complaint-Affidavit in support of the charges for Violation
of Batas Pambansa Bilang 22 against the said Mercedes Santiago, who may be served
with subpoena and other processes of this Honorable Office at her last known address
at No. 66 Maginhawa St., Teachers Village, Quezon City, Philippines;
IN WITNESS WHEREOF, I have hereunto set my hand this 16 January 2015 at Quezon
City, Philippines.
COMPLAINANT
SUBSCRIBED AND SWORN to before me this 17 January 2015 at Quezon City. I
hereby certify that I have examined the Affiant and that I am fully satisfied that she has
voluntarily executed and understood the contents of her Complaint-Affidavit.
Administering Officer