REPUBLIC OF THE
PHILIPPINES
OFFICE OF THE CITY PROSECUTOR
CITY OF DASMARIÑAS
MS. MARY ANN M. MALALUAN
Respondent
COMPLAINT AFFIDAVIT
I, Mark Alvin F. Jovido, Filipino, of legal age, with postal address at at Blk1 Lot 32
Green Valley Detachment, Molino 2. Bacoor Cavite, after being duly sworn in to accordance
with law, hereby depose and say:
1. That I am employed as a Legal Officer of EQGRANT LENDING CORP., a lending company
duly organized and existing under and by virtue of laws of the Philippines with principal
address at 3Roze Building, Governor’s Drive, Sampaloc 1, Dasmariñas City, Cavite. `
2. That as Legal Officer of the company, my duties include, monitoring and collection of
delinquent accounts or past due accounts, delivery of demand letters and represent the
company in cases against delinquent borrowers of all the branches of the company.
3. That I am authorized by the company to file a criminal case for violation of Batas Pambansa
Bilang 22 against principal borrower Ms. Mary Ann M. Malaluan who can be served with
summon at her residence at 207 Barangay I, Mataas na Kahoy, Batangas Province and at
her business. Attached hereto as Annex “A” the Secretary Certificate authorizing me
to represent the company.
4. On 16 March 2019, principal borrower Ms. Mary Ann M. Malaluan applied for a loan and
was granted by EQGRANT LENDING CORP.,- Lipa City Branch in the amount of Three
Hundred Thousand Pesos (Php300,000.00) with an interest of 3.5% per month for twelve
(12) months. Ms. Mary Ann M. Malaluan executed a Promissory Note in the amount of
Four Hundred Twenty Six Thousand Pesos (Php426,000.00). Copy of Promissory
Note is hereto attached as Annex “B”.
5. Simultaneous with obtaining the loan from the our company (Dasmariñas City Branch) Ms.
Mary Ann M. Malaluan issued and delivered the post-dated checks as payment for his
amortization to EQGRANT LENDING CORP. - Dasmariñas City Branch located at 3Roze
Building, Governor’s Drive, Sampaloc 1, Dasmariñas City and within the jurisdiction of this
Honorable Office, Bank of the Philippine Islands – Imus, Cavite checks in payment of her
obligations covered by the Promissory Note.
The respondents issued a several checks and these initial TWO (2) among the several
checks are the subject of this case amounting to Php 85,002.00, to wit:
BPI – Imus Branch 0435901 March 28, 2020 Php 28,334.00
BPI – Imus Branch 0435902 April 13, 2020 Php 28,334.00
BPI – Imus Branch 0435903 April 28, 2020 Php 28,334.00
6. When presented to our Chinabank - SM Dasmariñas City Branch, our company depository
bank were dishonored due to ACCOUNT CLOSED. Copies of the front and dorsal portions
of the checks are hereto attached as Annexes “C”,“D”, “E”.
7. Likewise, written and verbal demands through demand letters and collection follow up to
settle the obligation were made but Ms. Lucy Hao Sy refused and failed and continues to
refuse and fail to pay their just and valid obligation.
8. As a result of the failure of Ms. Lucy Hao Sy, to make good of the checks, the company
was constrained to engage the services of a counsel and paid an amount of Php 20,000.00
for the acceptance fee plus Php 3,000.00 per appearance in the hearings.
9. Herein attached are the Demand Letters personally delivered to the residence of Ms. Lucy
Hao Sy on _____________ . Marked as ANNEX “E”
10. I am executing this Affidavit to attest to the truthfulness of the foregoing and for the
purpose of charging Ms. Lucy Hao Sy, of Three (3) counts of violation of Batas
Pambansa Blg. 22.
IN WITNESS WHEREOF, I have affixed my signature this _____ day of January 2021
in Dasmariñas City, Cavite, Philippines.
Affiant
SUBSCRIBED AND SWORN to before me this ____ day of January 2021 in
Dasmariñas City, Province of Cavite. I further certify that I have personally examined
the Affiant and I am satisfied that she voluntarily executed her Counter-Affidavit and
that she understood the contents of the same.
CITY PROSECUTOR
CERTIFICATION
This is to certify that I have personally examined the affiant and I am convinced that he
has fully executed this Complain-Affidavit, read the same and understood the contents
thereof and that the allegation therein are true and correct of his personal knowledge and
based on the authentic documents in his possession.
CITY PROSECUTOR
