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 a manager check issued by the bank and withdrawn by the respondent.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