REPUBLIC OF THE PHILIPPIN PHILIPPINES} ES} DONE: IN THE CITY OF BAGUIO } S.S. X =========================== X
COMPLAINT-AFFIDAVIT
That Th at I, AMANDA T. MONTEJO, of legal age, married, Filipino and a resident of No. 44 2 nd Road, Quezon Hill, Baguio City, after having been duly sworn to in according to law hereby depose and say: 1 That That I am the Loan Manag Manager er of Union Union Bank, Bank, Sessio Session n BranchBranch-Bag Baguio uio City. I am executing this affidavit in behalf of Union Bank, being the complainant therein; 2 In behalf behalf of the the said Bank, Bank, I am filing filing a formal formal compl complain aintt for Estafa Estafa through throu gh Fals Falsifica ification tion of Publ Public ic Docu Document ment and/o and/orr throu through gh Forge Forgery ry agaain ag inst st res esp pon onde den nt RO ROSA SAM MIA U. GU GUA ANZ NZO ON [he here reiina naffte terr “Respondent”], a resident of # 125 West Quirino Hill, Baguio City; 3 On September 3, 2013, Respondent using the name of, and misr mi srep epre rese sent ntin ing g he hers rsel elff to be NA NATH THAL ALIE IE KA KAE E FO FORT RTAL ALEJ EJOONAVARRO, submitted a loan application, purportedly signed by the Spou Sp ouse ses, s, by fo forg rgin ing g th thei eirr si sign gnat atur ures es wi with th Un Unio ion n Ba Bank nk,, Se Sess ssio ion n Branch-Baguio City, amounting to Php5,000,000.0 Php5,000,000.00; 0; 4 As security security for the the payment payment of the the said loan, Respo Respondent ndent subm submitted itted as collateral thereof a parcel of land described in TCT No. T-127891, and executed a Real Estate Mortgage over the said land in favor of Union Bank; 5 On No Nove vemb mber er 11 11,, 20 2018 18,, th thee lo loan an ap appl plic icat atio ion n am amou ount ntin ing g to Fi Five ve Million Pesos (Php5,000,000.00) was approved by Union Bank and the proceeds thereof were delivered to the Respondent, receipt of which is evidenced by a manager’s check issued by the bank and withdrawn by the Respondent, a copy of the said check is hereto attached as Annex “A” hereof; 6 On De Dece cemb mber er 11 11,, 20 2018 18,, Su Summ mmit it Ba Bank nk fo foun und d ou outt th that at re resp spon onde dent nt falsified and/or forged the above mentioned documents, it also found outt th ou that at re resp spon onde dent nt mi misr srep epre rese sent nted ed he hers rsel elff to be Na Nath thal alie ie Ka Kaee Fortalejo-Navarro when in truth and in fact the former, as found by the ban bank k is Ros Rosami amiaa U. Gua Guanzo nzon. n. Res Respon ponden dent’s t’s rea reall ide identi ntity ty was discovered by the bank when one of its employees identified her as an acquaintance as they live in the same barangay and is personally known to her;
7 Respondent’s unlawful acts were discovered by the bank when the latter tried to collect from the Spouses Navarro who refused to pay on the ground that they did not apply for a loan, much less mortgage the land covered by subject land title in favor of Union Bank; 8 The unlawful acts by Respondent caused damage and prejudice to Union Bank in the amount of Php5,000,000.00, the amount released to respondent as proceeds of the loan, including interest of twelve percent (12%) per annum; 9 Union Bank spent Php30,000.00 for attorney’s fees for filing the complaint affidavit; 10 That I am executing this affidavit for and in behalf of the Union Bank Session Branch-Baguio City, being the Loan Manager thereof, to file a formal complaint of Estafa through Falsification of Public Document and/or through Forgery against Rosamia U. Guanzon.
IN WITNESS WHEREOF, I have hereunto affixed my signature for
and in behalf of the complainant Union Bank Session Branch-Baguio City, this 14th day of October 2019, at Baguio City, Philippines.
AMANDA T. MONTEJO
Affiant
SUBSCRIBED AND SWORN to
before me in the City of Baguio,
this 14th day of October 2019.
ATTY. JONA B. REYES
Investigating Prosecutor
CERTIFICATION
I hereby certify that I have personally examined the above named affiant and that the foregoing statements were given by her voluntarily and of her own free will and that she understood her affidavit.
ATTY. JONA B. REYES
Investigating Prosecuto
