Republic of the Philippines
City of Tacurong
COMPLAINT – AFFIDAVIT
That I, Cheryl T. Pueblo, of legal age, single, Filipino and a resident of EJC
Montilla, Tacurong City, after having been duly sworn to according to law hereby
depose and say:
1. That I am the Loan Manager of Souht Bank, Tacurong Branch, Tacurong
City. I am executing this affidavit in behalf of South Bank, being the
complainant herein.
2. In behalf of the said Rural Bank, I am filing complaint for Estafa thru
Falsification of Public Document against respondent Norhatima D. Aljani, a
resident of Montivello, Tacurong City.
3. On January 4, 2019, respondent using the name of, and misrepresenting
herself to be Dona Angel Dela Cruz, submitted a loan application,
purportedly signed by tge Spouses, by forging their signatures with South
Bank, Tacurong City amounting to Php1 000 000.00.
4. As security for the payment of the said loan, respondent submitted as
collateral thereof a parcel of land described in TCT No. T-171819 and
executed a real estate mortgage over the said land in favour of South
Bank.
5. On January 14, 2019, the loan application amounting to one million pesos
(Php 1 000 000.00) was approved by South Bank and the proceeds
thereof were delivered to the respondent, receipt of which is evidenced by
a manager check issued by the bank and withdrawn by the respondent.
Photocopy of the said check is hereto attached as Annex C hereof.
6. On January 14, 2019, South Bank found out that respondent falsified and
forged the above mentioned documents. It also found out that respondent
misrepresented herself to be Dona Angel Dela Cruz when in truth and in
fact the former, as found by the bank is Norhatima D. aljani. Respondent’s
real identity was discovered by the bank when one of its employees
identified her as an ex-girlfriend of her boyfriend and is personally known
to her.
7. Respondent’s unlawful acts were discovered by the bank where the latter
tried to collect from the Spouses Dela Cruz 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 favour of South Bank.
8. The unlawful acts by the respondent caused damage and prejudiced to
South Bank in the amount of Php 1 000 000.00 the amount released to the
respondent as proceeds of the loan, including interest of 12% per annum.
9. South Bank spent Php30 000.00 for attorney’s fees for filing the complaint
affidavit.
10. That I am executing this affidavit for and behalf of the South Bank,
Tacurong Branch, Tacurong City, being the Loan Manager thereof to file a
formal complaint of Estafa through Falsification of Public Document.
IN WITNESS WHEROF, I have hereunto affixed my signature for and in
behalf of the complaint South Bank, Tacurong Branch, Tacurong City this 21 st
day of January 2019, a Tacurong City.
CHERYL T. PUEBLO
Affiant
SUBSCRIBED and SWORN to before me this 21st day of January 2019
at Tacurong City. I hereby certify that I have personally examined the above
named affiant and that I am satisfied that the foregoing statements were given
by him voluntarily and of his own free will.
ATTY. EDWIN H. BARAQUIA
Prosecutor