REPUBLIC OF THE PHILIPPINES) CITY OF MALOLOS )s.s.

COMPLAINTAFFIDAVIT
I, Maria Antonina S. San Diego of legal age, Filipina, and with residence at 65 Lugam City of Malolos, Bulacan, after having been sworn to in accordance with law, do hereby depose and state that: 1. Lilian de Guzman was a client of Rosario Victoria who is my sales agent to whom I entrusted some pieces of jewelry on consignment basis. Sometime in January 2011, Lilian de Guzman, went to see me in my house, to talk to me about paying directly the jewelry, not paying thru Rosario Victoria to be able to get better terms of payment. Rosario Victoria and Lilian de Guzman and I agreed to such arrangement. Hoping that she pays me on time without me reminding Rosario Victoria constantly. For which Lilian de Guzman issued me several Planters Bank amounting to 1,053,500.00. In our first transaction as a direct client, I had hard collecting payment from her. Her personal checks were dishonored and eventually her account was closed. She paid several of those dishonored checks in cash. Balance amounting to P 569,500.00 remain unpaid as of to date. On August 2011, she again issued me sixteen postdated checks (16) of Cooperative Rural Bank of Bulacan, (Longos Branch) intended to cover the amount of dishonored checks as well as the payment for her remaining balance for value received from Rosario Victoria. Details of which are as follows: Bank /Check # CRBB Rural Bank/Check # 8973171 CRBB Rural Bank Check # 8973172 CRBB Rural Bank Check # 8973173 CRBB Rural Bank Check # 8973174 CRBB Rural Bank Check # 8973175 CRBB Rural Bank Check # 8973176 CRBB Rural Bank Check # 8973177 Date September 1, 2011 October 1, 2011 November 1, 2011 December 1, 2011 January 1, 2011 February 1, 2011 March 1, 2011 Amount (PHP) 40,000.00 40,000.00 40,000.00 40,000,00 40,000.00 40,000.00 40,000.00 Status Closed Account Closed Account Closed Account Closed Account Closed Account Closed Account Closed Account

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CRBB Rural Bank Check # 8973178 CRBB Rural Bank Check# 8973179 CRBB Rural Bank Check # 8973180 CRBB Rural Bank Check# 8973181 CRBB Rural Bank Check # 8973182 CRBB Rural Bank Check # 8973183 CRBB Rural Bank Check # 8973184 4.

April 1, 2011 May 1, 2012 June 1, 2012 July 1, 2012 August 1, 2012 October 1, 2012 November 1,2012

40,000.00 40,000.00 40,000.00 40,000.00 40,000.00 40,000,00 49,000.00

Closed Account Closed Account Closed Account Closed Account Not yet deposited Not yet deposited Not yet deposited

However, on September 2011 after seven (7) months of the said arrangement, her September 1, 2011 check payment amounting to P40, 000.00 drawn from Cooperative Rural Bank of Bulacan was dishonored again on a status that it is a closed account. A photocopy of the issued checks is attached as Annex A. I promptly notified her of the subsequent dishonor of her checks and likewise sent her a DEMAND LETTER through my Lawyer Atty. Macario De Guia. She then personally went to our house and was able to talk to my husband Dennis D. San Diego, because at that time I was out of the house. Verbally, she promised to return some pieces of jewelry and to pay her obligations on January 2012. Then again, she never made good of her promise. To return some pieces of jewelry and to pay the outstanding amount she owes me. In view of Lilian De Guzman obstinate refusal to pay after texting her, calling her regarding her promise to pay and the continuous bank dishonoring her checks, I referred the matter again to my legal counsel, who accordingly sent a second DEMAND LETTER to Ms. De Guzman, to pay her outstanding obligation specifically the checks dated September 1, 2011 to January 1, 2012 Cooperative Rural Bank of Bulacan. Attached as Annexes ____

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7. Despite her receipt of the DEMAND LETTER dated___ , Lilian De Guzman still failed to pay her outstanding obligations and still fail and refuse to pay her indebtedness. The Cooperative Rural Bank of Bulacan checks she issued for the months of September 1 2011 to January 1 2012 are already closed accounts. 8. As result of nonpayment of the outstanding obligations of Lilian de Guzman I suffered damages of lost in income in the amount of P 569,500.00.00

9. Also, as a result of Lilian de Guzman issuance of worthless checks, I suffered actual damages in the amount P_____ plus interest thereon as well as moral damages and attorneys fee. 10. In view of the foregoing, I hereby execute this affidavit to initiate a complaint for fourteen (14) counts of violation of B.P. Blg. 22 or the Bouncing Checks Law /ESTAFA against Lilian De Guzman who resides at Florida Villas Longos, City of Mololos, Bulacan. All allegations in this affidavit are based on my personal belief and knowledge of the said facts.

Maria Antonina S. San Diego Affiant