Republic of the Philippines )

City of Manila

)s.s

COMPLAINT AFFIDAVIT

I, NABS ESPINO, Filipino, of legal age, single, and resident of #70 Espana
Grand, Tolentino St., Sampaloc, Manila, Philippines, after being sworn in accordance
with law do hereby depose and state:
1. That, I am engaged in the business of buying and selling of new and used
automobiles with a shop located at Blumentrit, Manila City.
2. That, I have known of the Spouses Jeric and Luna De Guzman through the
person of Kris De Guzman, a resident of Lot 12 Block 85, Yen St., North
Fairview Subdivision, Quezon City, Philippines;
3. That, Upon learning of Kris De Guzmans desire to buy a car, I approached
her and introduce my 2014 BMW with plate no. MPH-375 worth P 3,000,
000.00, wherein she shows her willingness to buy and therefrom started our
sale transactions.
4. That, sometime in the morning of February 9, 2015 at Sampaloc, Manila,
Philippines, Kris De Guzman using the Bank of the Philippine Island check
issued by her parents Mr. and Mrs. Jerick and Luna De Guzman with check
number 325851 in the amount of P 3, 000, 000.00 as supposed payment for the
said 2014 BMW with plate no. MPH-375; and that the said spouses new of the
said check issuance as they simply gave Kris a blank check and told her to just
fill in the date and the name of the payee. They also told her to personally
execute the deed of sale so that she can have it registered in her name.
5. That, said check was drawn against the account of the Spouses Jeric and Luna
De Guzman, at the Bank of the Philippine Islands at U.N Avenue Branch with
Account No. 4034197901088233;
6. That, at the time said Kris De Guzman handed 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;
7. That, 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.
8. That, when Spouses Jeric and Luna De Guzman, failed to heed my demands,
I endorsed the said check to my legal counsel who immediately sent a formal
demand letter through a registered mail with a return card on February 28,
2015 which was received by them on the same date.

9. That, as of date however, Respondents has unjustifiably ignored all these

demands to pay the said account and/or to redeem the said return check. A
true and faithful machine reproduction of my demand letter dated February
25, 2015 is hereto attached as Annex A.
10. That, I am therefore executing this Complaint-Affidavit in support of the
charges for Violation of Batas Pambansa Bilang 22 against Spouses Jeric and
Luna De Guzman, Respondents, who may be served with subpoena and other
purposes of this Honorable Office at her last known address at Lot 12 Block
85, Yen St., North Fairview Subdivision, Quezon City, Philippines.
FURTHER AFFIANT SAYETH NAUGHT.

IN WITNESS WHEREOF, I have hereunto set my hand this 15th day of March 2015 at
Marcelino St., Pedro Gil, Malate, Manila City Philippines.

________________
NABS ESPINO
Affiant

CERTIFICATION

SUBSCRIBE AND SWORN to before me this 15th day of March at Marcelino St., Pedro
Gil, Malate, Manila City Philippines.
I hereby certify that I have examined the Affiant and that I am fully satisfied that he has
voluntarily executed and understood the contents of his Complaint-Affidavit.

Doc. No. ___

Page No. ___
Book No.___
Series of 2016

Atty. Janelle Flores

Notary Public
Until December 31, 2018
PTR#0915886-01/30/15
Attorneys Roll #9460