Republic of the Philippines

DEPARTMENT OF JUSTICE
National Prosecutorial Service
OFFICE OF THE CITY PROSECUTOR
Hall of Justice, Santiago City

VINCENT BACANI PUA,

Complainant,

-versus- I.S. No.__________________

For Estafa under
Art.315,par.2(a)

ANTHONY DE GUZMAN INOCENCIO

Respondent
x---------------------------------------------x

AFFIDAVIT-COMPLAINT

I, Vincent Bacani Pua, 25 years old, single, Filipino citizen

and a resident of Mazda Street, St.James, Batal, Santiago City, after
having duly sworn to in accordance with law do hereby depose and
say :

1. That I am formally charging respondent ANTHONY DE

GUZMAN INOCENCIO,38 years old, married, Filipino citizen and a
resident of Sitio Pulo, Barangay Dolores, Capas, Tarlac for the crime
of ESTAFA penalized under Article 315 par.2(a) of the Revised Penal
Code, committed as follows, to wit:

a) That I personally known the respondent also known as

Anjoe for almost three(3) years as a businessman and a former
factory worker for six(6) years in South Korea,

b) That respondent is the sole proprietor of Cagayan Valley

Korean Language Tutorial Center(CVKLTC for short) located at 2 nd
floor, Bustamante Building, Maharlika Highway, Victory Norte,
Santiago City,
 c) That CVKLTC and other branches situated in Region 2 is
engaged in business in teaching Korean language to any person
who is interested to learn the same for a fee,

d) That I and my girlfriend trusted the respondent wholly and

without any reservation particularly in monetary dealings because
the respondent himself personally gave backpay and allowance to
my girlfriend when she left and worked to South Korea as factory
worker,

e) Sometime during the month of February 2017, I heard an

information that the respondent is conveying the management and
affairs of CVKLTC and other branches in Region 2 because
according to the respondent, he wanted to establish tutorial center
within Metro Manila,

f) But the truth of the matter is that CVKLTC and other

branches in Region 2 incurred unpaid tax liabilities( tax maped) due
to respondents failure to settle its obligations,

i) That on 22 February 2017, my girlfriend told me that she

had a chance to talked with the respondent regarding the status of
CVKLTC Santiago Branch and she was convinced by the respondent
to take over the management and affairs of the said CVKLTC for
Two Hundred Thousand Pesos(Php200,000.00),

j) On the same date, my girlfriend told me to verify with the

respondent if there is irregularity in the business affairs and the
actual management and transactions of CVKLTC,

k) That I personally met the respondent to inquire and confirm

from him if we could immediately take over the management and
affairs of CVKLTC after paying the Two Hundred Thousand
Pesos(Php200,000.00),

l) The respondent assured me and guaranteed that right after

the amount of Two Hundred Thousand Pesos(Php200,000.00) has
been paid, we(I and my girlfriend) could immediately take control of
CVKLTC,

m) We relied and trusted the statements made by the

respondent and made an agreement on how payment would be
made;
 n) The respondent set February 27, 2017 at the office of Atty.
Lucky M. Damasen as an scheduled date and venue to make a
Memorandum of Agreement in order to legalize and settle our
transactions;

o) On 27 February 2017, I personally met the respondent and

we both proceeded to the office of Atty. Lucky M. Damasen in order
to legally formalize our agreement. Memorandum of Agreement[1] is
attached herein and made an integral part hereof;

p) The total amount of Two Hundred Thousand

Pesos(Php200,000.00) that we earned was used to pay the
respondent relying from his acts and statements that we(I and my
girlfriend) will take over the management and affairs of CVKLTC;

q) But when I visited CVKLTC to inspect the area, I was

surprised when I met Angie Bulan and introduced herself to be the
manager of CVKLTC;

r) I could not imagine that at a certain instant, the respondent

made such false pretenses, fraudulent acts and fraudulent means
to convince us to part our hard earned money amounting Two
Hundred Thousand Pesos(Php200,000.00),

s) As a result thereof, I immediately called the respondent

about the prejudiced that I and my girlfriend suffered but he did not
answered my calls,

t) On 25 April 2017, I seek the legal assistance of Atty. Lucky

Damasen and a demand letter addressed to the respondent
involving the Two Hundred Thousand Pesos(Php200,000.00) that
the he received and a possible filing of criminal complaint for
Estafa[2];

________________
[1]Annex A
[2]Annex B
 IN WITNESS WHEREOF, I have hereunto set my hand this
25th day of May 2017, at Santiago City,Isabela.

VINCENT BACANI PUA

Complainant
Drivers Lic.no.B12-11-001546

SUBSCRIBED AND SWORN before me this 25th day of May

2017, at Santiago City Philippines; Affiant exhibited to me his
identifying evidence as required by the Rules, who signed the said
instrument in my presence. I further certify that I have personally
examined the affiant and I am convinced that the same is his own
free and voluntary act and deed.

_______________________
Prosecutor