Republic of the Philippines

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
Office of the City Prosecutor
Lapu-lapu City, Cebu

HILLS FINANCE CORPORATION,

Complainant,

NPS DOCKET NO. _____

-versusMARY LOUISE G. BALTAZAR, CECILE J. SURBANO,

FLORY MAE C. UNITO AND RENEDE E. YAPE,

Respondents,
X---------------------------------------------------------------X
AFFIDAVIT- COMPLAINT
I, NATIVIDAD B. NADUNZA, of legal age, Filipino and a resident of
Barangay 1, Malaybalay City, Bukidnon, after being duly sworn in accordance
with law, hereby depose and state:

Q1: Do you swear to tell the truth and nothing but the truth in this
Affidavit - Complaint?
A1: Yes, I do.
Q2: Are you aware that in answering questions you are under
oath and you may face criminal liability for false testimony or
perjury if you will not tell the truth?
A2: Yes, I am aware.
Q3: Please state your name, age and address.
A3: I am Natividad B. Nadunza, of legal age, Filipino and a
resident of Barangay 1, Malaybalay City, Bukidnon,
Philippines. I am the Department Head of the Internal
Monitoring and Audit Department (IMAD) of Hills Finance
Corporation (formerly Hills Small Loans), a corporation duly
formed and existing under and by virtue of the laws of the
Affidavit-Complaint: Colin Parsons vs. Arlyn M. Parsons

Philippines, with principal office address at Sta. Ana

Building, Fortich Street, Malaybalay City, Bukidnon.
Q4: What is your purpose in giving this statement?
A4: To file a criminal case in behalf of Hills Finance Corporation
against its former employees MARY LOUISE G.
BALTAZAR of St. Jude Acre, Sasuman Apt., Climaco St.,
Bulacao, Cebu City, CECILE J. SURBANO of
Impalambong, Malaybalay City, Bukidnon, FLORY MAE C.
UNITO of Lower Tiparak Tambulig, Zamboanga del Sur and
RENEDE E. YAPE of Matu-og, Tayasan, all of legal age,
Filipino citizens, for their unlawful acts committed against
Hills Finance Corporation;
Q5: Are you authorized to file this case?
A5: Yes, I am duly authorized to represent the complainant, Hills
Finance Corporation as manifested in Board Resolution No.
2014-10, a copy thereto is herein attached and made as an
integral part as Annex A.
Q6: What services or products does Hills Finance Corporation
render or provide, if any?
A6: Hills Finance Corporation offers loans such as Salary Loan,
Cash Advance Loan and Other Cash Loan charged to
salary, bonuses and other incentives of client-borrowers.
Q7: How can a client avail of these loan programs?
A7: A client-borrower can apply for a salary loan chargeable to
his salary from his employment. If the clientborrower/account holder has an existing salary loan at
Hills Finance Corporation, he can avail of the cash
advance loan and other cash loan chargeable to his
bonus and other incentives.
Q8: What is the standard procedure of Hills Finance Corporation
in the application, approval and release of the salary loan
program?
A8: The client- borrower/ account holder has to apply first for the
loan by filling up and signing a Promissory Note. His
account will then be verified by the Account Officer through
Affidavit-Complaint: Colin Parsons vs. Arlyn M. Parsons

Credit Investigation/Background Inspection (CI/BI) to

determine if the client- borrower is qualified to apply and as
to how much amount of loan may be granted. After
submission of the Promissory Note and verification of
information, the application will be forwarded to the Branch
Manager for approval. Once approved, the Cashier will
release the loaned amount to the client- borrower and a
Cash Voucher will be issued to the client- borrower for
signature as proof that he has received the loaned amount.
Q9: You mentioned earlier that you want to file criminal cases
against former employees of Hills Finance Corporation
MARY LOUISE G. BALTAZAR, CECILE J. SURBANO,
FLORY MAE C. UNITO and RENEDE E. YAPE, who are
they?
A9: These three were former employees of Hills Finance
Corporation. MARY LOUISE G. BALTAZAR was a Branch
Manager of Hills Finance Corporation - Lapu-lapu Branch.
CECILE J. SURBANO was a Cashier, FLORY MAE C.
UNITO was a Data Encoder and RENEDE E. YAPE was an
Account Officer of the same branch.
Q10: As former employees of HFC Lapu-lapu Branch, what
were their duties and responsibilities relative to the approval
and release of loans to clients borrowers?
A10: As a Branch Manager, the main function of MARY LOUISE
G. BALTAZAR is to approve the loan application after
verification of the transaction documents including the
genuineness of the signatures appearing therein. Once
approved, the task of the Cashier - CECILE J. SURBANO is
to release the loaned amount to the client- borrower. Once
the loaned amount is released, the Data Encoder FLORY
MAE C. UNITO will encode the account in the computerized
system of Hills Finance Corporation for record purposes.
Lastly, the Account Officer - RENEDE E. YAPE is tasked to
conduct Credit Investigation/Background Inspection (CI/BI)
and to collect the amortization payment of the clientborrower.
In such capacity, the three handled and serviced clientsborrowers of Hills Finance Corporation, had access to
sensitive and confidential information pertaining to the

Affidavit-Complaint: Colin Parsons vs. Arlyn M. Parsons

accounts and enjoyed high degree of confidence from both

Hills Finance Corporation and the client-borrowers.
Q11: Why are you filing this criminal case against Mary Louise
G. Baltazar, Cecile J. Surbano, Flory Mae C. Unito and
Renede E. Yape?
A11: I am filing this complaint in behalf of Hills Finance
Corporation because of fraudulent transactions and
irregularities facilitates and committed by Mary Louise G.
Baltazar, Cecile J. Surbano, Flory Mae C. Unito and
Renede E. Yape in connivance and collusion with each
other which enabled them to gain for themselves, to the
damage and prejudice of Hills Finance Corporation in the
total sum of TWENTY SEVEN THOUSAND NINE
HUNDRED FORTY EIGHT PESOS (Php 27, 948.00).
Q12: How did you find out about the fraudulent transactions and
irregularities facilitates and committed by Mary Louise G.
Baltazar, Cecile J. Surbano, Flory Mae C. Unito and
Renede E. Yape?
A12: I found out about these fraudulent transactions and
irregularities after the special audit/inspection conducted by
the Institutional Monitoring and Audit Department of Hills
Finance Corporation September 22, 2014 in our Lapu-lapu
Branch.
Q13: You also mentioned earlier about the second incident, can
you narrate the facts of this incident?
A13: Yes, I can. At about 7:30 AM of December 2, 2013, I went to
our conjugal house at Dologon, Maramag, Bukidnon to
fetch my son Charles and take him to his school at CMU
Nursery School. The teacher of my son informed me by text
and dialogue that Charles refused to attend his classes
unless I personally took him to school. Sometimes, Charles
would attend class but would be crying asking that he goes
home early because Charles wants to see me and I have to
take him to school.
I and my son Charles were about to leave for school
when my wife came out of our conjugal house and started
to nag me about the incident last November 27, 2013. She
was clearly irrational and paranoid.
Affidavit-Complaint: Colin Parsons vs. Arlyn M. Parsons

In fact, she threatened that she will shoot herself in the

head with a gun in front of our son, Charles, if I will tell the
police that her son from her previous marriage, Raymund
M. Pacana is hiding from the police at our conjugal house.
I kept telling her to calm down especially that our son
Charles is listening to what she was saying and her
statement causes threat and intimidation against me and
the life of my son, Charles. She demanded that I leave our
conjugal house and she will be the one to take our son,
Charles to school. To appease my wife, I left and waited for
my son outside the school to make sure that he gets to
class but my wife and my son never showed up.
Because of the threat made by my wife that she will
shoot herself in the head with a gun, I went to the Maramag
Police Station to report the incident. I was issued a Blotter
Extract herein attached as Annex B.
Q14: How about the third incident that occurred on December 3,
2013, can you narrate what happened?
A14: Yes, I can. I was worried for my children especially with
the state of mind of my wife so I again went to our conjugal
house on December 3, 2013. I brought with me food and
snacks for my children.
Due to my fear brought about by the threats and
intimidation caused by my wife, I asked my friend SPO1
Warren Coales to accompany me to our conjugal house to
visit my children and to give them food. Upon entering the
gate of the house, my wife Arlyn Parsons came out of the
house and quarreled with me. I kept telling her to calm
down. Our son, Charles, came out of the house and I
played with him. My wife kept nagging me but I did not give
her attention because she has always been like that even in
the past. Several minutes after, Arlyn left and went towards
the back of our conjugal house and when she emerged
thereto she already had a short firearm in her hand.
While walking towards me, Arlyn pointed a gun at me
and demanded that I leave. While pointing a gun at me,
Arlyn uttered Visayan words that my friend SPO1 Warren
Coales translated as Pusilon ta ka karon. Malas ka kay
nakatunong ka ug pamilya nga dili mahadlok mopatay. (I
Affidavit-Complaint: Colin Parsons vs. Arlyn M. Parsons

will shoot you. You are unfortunate that you came by a

family that is not afraid to kill). Arlyn clearly intended to
cause injury to me with the use of the gun. As a warning
shot, Arlyn pointed the gun upwards in the air and fired one
shot. Several seconds after the warning shot, her son from
her previous marriage, Raymund M. Pacana, immediately
run towards her and restrained Arlyn and grabbed the short
firearm to stop her from pursuing her intention to inflict
injuries to me.
Because of fear for our lives and as advised by SPO1
Warren Coales, we left the conjugal house and went
directly to Maramag Police Station to seek assistance and
report the case.
A Blotter Extract was executed and herein attached
as Annex C. This incident was personally witnessed by
SPO1 Warren Coales and he executed an Affidavit of
Witness herein attached as Annex D.

Q15: As to the fourth incident, can you narrate what happened?

A15: Yes, I can. On February 28, 2014, at about 9:30 AM, I
went to Musuan Elementary School for my daughter Maria
Johanna Edithas King and Queen of Hearts Competition. I
was accompanied by Glenn Coales. Arlyn tried to have an
argument with me but I stayed calm. I asked Arlyn where
Johannah, my daughter, was but Arlyn did not answer the
question. I presented the food and snacks to Arlyn but she
refused to take it. She continued nagging and trying to
make a scene. Glenn Coales told her that: Ayaw buhata
kay ma ulawan mo (Do not do this, you will get
embarassed). Suddenly, she picked up a rock and went
towards me intending to cause injury to me. She was about
to smash the rock at my face or chest but she desisted from
smashing it towards my face or chest. Instead, she threw
the rock at the ground. She then proceeded to talk to an
unknown person on her cellphone and gave the description
of the motorcycle that we used that day. She also identified
me and Glenn Coales as riders thereof and that we are
wearing helmets.
Glenn Coales, who was present when this incident
occurred, executed an Affidavit of Witness (herein attached
Affidavit-Complaint: Colin Parsons vs. Arlyn M. Parsons

as Annex E. According to the narration of Glenn Coales,

he saw and heard Arlyn Parsons utter the statement Gaw,
XRM pula naghelmet duha nga tao.
There was no other red motorcycle or any motorcycle
parked near where the incident happened. Clearly, she was
referring to the motorcycle of Glenn Coales and the two
riders referred were Glenn Coales and me.
Q16: Do you have other statements to make?
A16: None for now.
IN WITNESS WHEREOF, I hereunto set my hand this _____ day of
_____________ 2014, at Malaybalay City.

COLIN PARSONS
Affiant
SUBSCRIBED AND SWORN TO before me this ___ day of
__________ 2014, affiant exhibited to me his _________________________,
as sufficient proof of his identity. I hereby certify that I have personally
examined the above-named affiant and I am convinced that he fully
understood his averments and he so averred of his own free will and
volition.

Affidavit-Complaint: Colin Parsons vs. Arlyn M. Parsons

Affidavit-Complaint: Colin Parsons vs. Arlyn M. Parsons