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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


METROPOLITAN TRIAL COURT
MAKATI CITY, BRANCH x

BANK OF LUZON
Plaintiff,

-versus- CIVIL CASE NO. xxxx


For: SUM OF MONEY

JOSE REYES
Customer No. xxxxxxxxxx
Defendant,
X----------------------x

AFFIDAVIT

I, Athena R. Quero, of legal age, and resident of 26 Benefits Street, Project 8,


Quezon City, after having duly sworn to in accordance with law, hereby depose and say
that:

1. I am the current Account Specialist of herein plaintiff, Bank of Luzon, (referred


to as “BL”) a domestic corporation duly organized and existing under and by
virtue of Philippines laws, which is engaged in issuing credit cards using a card
operating system that is both information security and quality management
compliant as certified by the British Standard Information Security Management
System and International Standard Organization for Quality Management
System. The bank has a principal office located at Paseo de Roxas, Makati
City.

2. I am responsible for the recording and reporting of financial transactions,


general ledger bookkeeping, and bank statement reconciliations of herein
plaintiff. It is my tasks to monitor the records and payments of the bank
cardholders. I also issue demand letters to credit cardholders if they failed to
pay and comply to their obligations.

3. Before the issuance of the said credit card, the defendant agreed to the bank’s
terms and conditions which states that the defendant will pay all charges
incurred through the use of the aforesaid card within the period of twenty (20)
calendar days from the assigned cut-off date without the necessity of demand.
Reyes also agreed that 3.25% will be added to the remaining charge if he opt
to pay in minimum. Lastly. He also agreed that a 6% rate will be added in cases
of failure to pay on his part.

4. Jose Reyes, as the defendant in this case, applied for the issuance of a BL
Credit Card under Card No. xxxx-xxxx. Based on our records, Reyes failed to
pay his outstanding balance, making him a delinquent credit cardholder that
falls under my supervision. Documents such as registration form with the
defendant’s signature and the duplicate copy of the receiving form which states
that the defendant received the said BL card were marked as Exhibit “C-1” and
“C-2” respectively.

5. Because of the defendant’s numerous credit card transactions, he has an


outstanding balance of PhP 263, 817.11 as of September 6, 2009 plus finance
charge at the rate of 3.25% and late payment of charge of 6% per month from
October 5 until the defendant has successfully paid his total obligation.
6. Lastly, due to its failure to pay his obligations, a civil case was filed before the
Metropolitan Trial Court in Makati City, Branch x against herein defendant, Jose
Reyes.

IN WITNESS WHEREOF, I have hereunto set my hand this 30 day of November


2010 at Makati City.

ATHENA R. QUERO
Affiant

SUBSCRIBED AND SWORN to before me in the City of Makati this 30 day of


November 2010, affiant exhibited to me her Passport No. UC404xxxx issued at Manila
on March 4, 2008.

Doc. No. ____;


Page No. ____;
Book No. ____;
Series of 2010.

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