Republic of the Philippines

Department of Justice
Office of the City Prosecutor
Pasay City
JONATHAN R. BARQUIN
Complainant,
-versus -

I.S.No. ____________
For : Estafa
Art. 315 par.2,( a )
of the RPC

DEXTER C. CO, KIAT REAPORT

MARVIN NICOLO D.QUIENG,
CORAZON D. QUIENG,POCHOLO D. QUIENG
Respondents,
x .. x

COMPLAINT
I, JONATHAN R. BARQUIN, of legal age, Filipino , married with office
address at Rm,. 405, Margarita Bldg. No. 1203 J.P. Rizal St., Poblacion, Makati
City after having been sworn to in accordance with law hereby depose and
states:
1. That sometime 3rd week of October 2012, respondent Dexter C.
Co and his one of the officer of Shinyland Corporation , the former being the
President approached me to assist in the documentation from verification
and transfer of title of the property purchased by respondent located at 4719
Hintoloro St., V.Mapa St., Sta. Mesa Manila from the seller , Marcos De Jesus
for a fee;
2. That after the consummation of the sale , they again approached
me to assist to secure building permit, was at since herein complainant does
not engaged in a lending business plus the fact that he do not know the
background and integrity of the respondent, so much so the identity of her
parents, complainant declined her request;
3. That after a lengthy discussion and sweet talking of herein
respondent, he was able to convinced to borrow the money in behalf of her
parents and offered that the amount to be release shall earn a compounded
interest of 20% for a period of two ( 2 ) months provided that the papers of
their parents, proof of income and check will be submitted first for
evaluation, otherwise, without such documents the money will not be
release.
4. That on April 27, 2013, respondent called the complainant that
the documents are already to be shipped from Cagayan de Oro City to
complainants office address.
5. That on April 28, 2013, respondent again called the complainant
to release to her the money as the documents including the checks will

arrived soonest since they are in dire need of money. Complainant gaining
respondents trust and confidence deposited to her account with BDO
Account No. 870154796 Cagayan de Oro Branch last April 30,2013. Copy of
the deposit slip is hereto attached marked Annex A hereof;
6. That had it not with respondents assurances and promised that
she will send the documents especially the checks which would represent to
guarantee the faithful compliance of the obligation of the actual borrower, he
could have declined and could have not deposited the money in her favor,
however, with such deception, fraud committed by respondent she
succeeded with her evil intention;
7. That for failure of the respondent to comply with her obligation,
complainant sent a demand letter dated April 15,2014 at her given address
at No.12,27th St., Nazareth Subdivision, Cagayan de Oro City. Copy of the
demand letter and Official Receipt from LBC Express is hereto attached
marked as Annex B hereof;
8. That lately, we discovered that she left the country last 2013
without however, informing us of such fact, an acts which clearly evasion and
without intention of paying their obligation;
9. The complainants unrelentless efforts located the whereabouts of
the respondent at Riyadh, Saudi Arabia working as Staff Nurse at King
Abdulaziz Medical City, National Guard Hospital;
10. That they sent demand letter for the settlement of the
amount
of P 257,989.01, likewise, requested the superior officer of the
respondent to assist the claim of the complainant;Copy of the demand letter
and request letter to her superior office are hereto attached marked as
Annexes C to C-1 hereof;
11. The respondent whose attitude clearly taking advantage of the
situation to avoid payment of their obligation, has been remiss with the clear
intention of denying everything to the damage and prejudice of the
complainant;
12. The respondent on account of their failure to comply with their
obligation through misrepresentation, fraud and false pretenses, clearly
committed the crime of the Estafa under Article 315, paragraph 2 ( a ) of the
Revised Penal Code which provides;
Any person who shall defraud another by any of the means
mentioned herein below shall be punished by:
1st. The penalty of prision correccional in its maximum
period to prision mayor in its minimum period, if the amount
of the fraud is over 12,000.00 pesos but does not exceed
22,000.00 pesos, and if
such amount exceeds the latter sum, the penalty provided
in this paragraph shall be imposed in its maximum period,
adding one year for each additional 10,000.00 pesos, but

the total penalty which may be imposed shall not exceed

twenty years. In such cases, and in connection with the
accessory penalties which may be imposed under the
provisions of this Code, the penalty shall be termed prision
mayor or reclusion temporal, as the case may be.
xxx. paragraph 2 ( a ) . By means of any of the following false
pretenses or fraudulent acts executed prior to or
simultaneously with the commission of the fraud;
( a ).
By using fictitious name, or falsely pretending to
possess power, influence, qualifications,
property,
credit, agency, business or imaginary transactions, or by
means of other similar deceits;
13. It is very clear from the aforequoted provisions that herein
respondent committed the crime indicted.
14. All told, respondent is being charge for Estafa under Article
315, par. 2 ( a ) of the Revised Penal Code who could be served with legal
processes at her last known addresses at No. 12, 27 th St. Nazareth
Subdivision, Cagayan de Oro City or at her employers address c/o THE HEAD
OF OFFICE, ADULT CARDIOLOGY CENTER, KING ABDULAZIZ MEDICAL CITY,
NATIONAL GUARD HOSPITAL, P.O.BOX 22490, RIYADH, SAUDI ARABIA:
IN WITNESS WHEREOF, I have hereunto set my hand this ________
day of _______________, 2014 at Makati City, Philippines.

JONATHAN R. BARQUIN
Affiant

SUBSCRIBED AND SWORN to before me this ______ day of _____________,

2014 at Makati City , Philippines. I hereby certify that I have personally
examined the affiant and that I am satisfied that the Complaint was
executed of his own will and volition.

Asst. City Prosecutor