REPUBLIC OF THE PHILIPPINES )

QUEZON CITY ) S.S.

COMPLAINT-AFFIDAVIT

I, Ellen Adarna, of legal age, single, Filipino and a resident of Blue Ridge, Katipunan Heights, Quezon City,
after having been duly sworn to according to law hereby depose and say:

1. That I am the Loan Manager of PS Bank, Commonwealth Branch, Quezon City. I am executing this affidavit
in behalf of PS Bank, being the complainant herein.

2. In behalf of the said PS Bank, I am filing a formal complaint for Estafa thru Falsification of Public Document
and/or thru Forgery against respondent Sam Pinto [hereinafter “Respondent”], a resident of Barangay Culiat,
Pasong Tamo, Quezon City.

3. On January 15, 2019, Respondent using the name of, and misrepresenting herself to be Doña Isabel Daza,
submitted a loan application, with a forged signature by the latter with PS Bank, Commonwealth Branch,
Quezon City amounting to PhP 5,000,000.00.

4. As security for the payment of the said loan, Respondent submitted as collateral thereof a parcel of land
described in TCT No. T-12341 and executed a Real Estate Mortgage over the said land in favor of PS Bank.2

5. On February 15, 2019, the loan application amounting to Five Million Philippine Pesos (PHP 5,000,000.00)
was approved by PS Bank and the proceeds thereof were delivered to the Respondent, receipt of which is
evidenced by a manager’s check issued by the bank and withdrawn by the Respondent. 3 Photocopy of the
said check is hereto attached as Annex C hereof.

6. On March 15, 2019, PS Bank found out that respondent submitted a false title of the collateral and that the
Respondent misrepresented herself to be Doña Isabel Daza when in truth and in fact the former, as found
by the bank, is Sam Pinto.4

7. Respondent’s real identity was subsequently discovered after an employee of the bank, Maine Mendoza,
saw Doña Isabel Daza's obituary printed in the Philippine Daily Inquirer last March 10, 2019. Shortly
thereafter, the TCT that was submitted to the LRA for verification was returned denying the existence of
such property.

8. The unlawful acts by Respondent caused damage and prejudice to PS Bank in the amount of PhP
5,000,000.00, the amount released to respondent as proceeds of the loan, including interest of six percent
(6%) per annum;

9. PS Bank spent PhP 30,000.00 for attorney’s fees for filing the complaint affidavit .

10. That I am executing this affidavit for and in behalf of the Bank, Commonwealth Branch, Quezon City, being
the Loan Manager thereof, to file a formal complaint of Estafa through Falsification of Public Documents
and/or through Forgery against Sam Pinto.

IN WITNESS WHEREOF, I have hereunto affixed my signature for and in behalf of the complainant Bank,
Commonwealth Branch, Quezon City this 8th day of April 2019, at Cagayan de Oro City.

Ellen Adarna
Affiant

SUBSCRIBED and SWORN to before me this 8th day of April, 2019, at Quezon 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.

John Lloyd Cruz

Associate Prosecution Attorney II

1
Annex “A”.
2
Annex “B”
3
Annex “C”.
4 Annex “D”.