Criminal Complaint: Republic of The Philippines Department of Justice City Prosecution Office Baguio City

Republic of the Philippines
DEPARTMENT OF JUSTICE
City Prosecution Office
Baguio City
BOY INOSENTE NPS-__________________

Complainant, For: Violation of B.P. 22
-versus-
GIRL TUSO
Respondent
x-------------------------------------x
CRIMINAL COMPLAINT
The undersigned complainant Boy Inosente of legal age, Filipino,
married and a resident of Brgy. Nursery, Baguio City under oath accuses
GIRL TUSO who is residing at Zone 2 Nino Jesus, Bato, Surigao for
violation of Batas PambansaBlg. 22 ,committed as follows:
“That on ________________ and ______________, at

Bato Surigao, respectively, above-named respondent, did and
there wilfully, unlawfully and feloniously, make, draw and
issue, two (2) post-dated United Coconut Planters Bank
(UCPB)- Naga City Branch Checks, to wit:
Check No. Date Issued Amount
in favour of complainant Boy Inosente as payment for the

Jewelry products that said respondent received from the
complainant, knowing fully well that at the time of issue she had
no sufficient funds and/or credit with the drawee bank for the
payment of said checks, and when said checks were presented for
payment and/ or encashment in UCPB – Baguio Branch, within
the jurisdiction of this Honorable Office, the same were
dishonoured and returned by the drawee bank for reason
“ACCOUNT CLOSED”, and despite notice of such dishonour,
said respondent failed and refused and still fails and refuses to
deposit with the drawee bank the amount necessary to cover said
check and/or make good the value thereof, to the damage and
prejudice of complainant in the abovementioned amount.
ACTS CONTRARY TO LAW.
Baguio City, Philippines, February _____, 2019.
BOY INOSENTE
Complainant
Witnesses/Exhibits:
1. Boy Inosente – Brgy. Nursery, Baguio City

2. Platinum Gold – Bula, Surigao
3. Others
SUBSCRIBED AND SWORN to before me

this_______day___________________ at Baguio City, Philippines by
the affiant whom I personally examined and I am satisfied the he
voluntarily executed and understood his said complaint.
Republic of the Philippines )
Province of Baguio )S.S.
COMPLAINT-AFFIDAVIT
I, BOY INOSENTE, of legal age, Filipino citizen, married, a

resident of Brgy. Nursery, Baguio City, after having been duly sworn to
in accordance with law, do hereby depose and say:
1. That on September 4, 2018 atBato, Surigao GIRL TUSOmade,

drew and issue in my favour post-dated UCPB Check, with
Check No. 17893758 with the amount of Php 33,615.00 as
payment for palm oil products delivered to and personally
received by Girl Tuso;
Copy of the above check and the delivery receipts is attached as

Annex “A” and Annex “B” series, respectively.
2. That on September 11, 2018 at Bato, Surigao GIRL

TUSOmade, drew and issue in my favour post-dated UCPB
Check, with Check No. 938905056 with the amount of
Php67,315.00 as payment for palm oil products delivered to and
personally received by Girl Tuso;
Copy of the above check is attached as Annex “C”.
3. That said checks were personally received by my staff Platinum

Gold as payment for the Jewelry delivered to Girl Tuso;
4. That when said checks were deposited in my bank account in

UCPB Baguio Branch and presented to the drawee bank for
payment, the two (2) checks were dishonoured and refused
payment for the reason “ACCOUNT CLOSED”;
5. That a Notice of Dishonor and Demand for Payment was mailed

to GIRL TUSO through registered mailed with the Philippine
Post Office, but the same was returned with the note “Refused
to receive”;
Copy of the “Notice of Dishonor and Demand for Payment with
proof of mailing is attached as Annex “E” and Annex “F”
respectively”.
6. That I kept on persuading GIRL TUSO to settle her accounts
however she refused to and still refuses to pay and make good
the value of said checks.
7. That because of the foregoing, I being the payee of said checks,

and being a micro entrepreneur, was prejudiced and suffered
damages in the amount above-mentioned.
8. I am executing this affidavit to attest the truth of the foregoing

statements and for the purpose of filing the necessary criminal
and/or civil action against GIRL TUSO.
IN WITNESS WHEREOF, I have hereunto set my hand this ___

day of February at Baguio City, Philippines.
BOY INOSENTE
Complainant
SUBSCRIBED AND SWORN to before me this_______day

___________________ at Baguio City, Philippines by the affiant whom
I personally examined and I am satisfied the he voluntarily executed and
understood his said affidavit.

Criminal Complaint: Republic of The Philippines Department of Justice City Prosecution Office Baguio City

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Republic of the Philippines

BOY INOSENTE NPS-__________________

“That on ________________ and ______________, at

in favour of complainant Boy Inosente as payment for the

ACTS CONTRARY TO LAW.

Baguio City, Philippines, February _____, 2019.

1. Boy Inosente – Brgy. Nursery, Baguio City

SUBSCRIBED AND SWORN to before me

I, BOY INOSENTE, of legal age, Filipino citizen, married, a

1. That on September 4, 2018 atBato, Surigao GIRL TUSOmade,

Copy of the above check and the delivery receipts is attached as

2. That on September 11, 2018 at Bato, Surigao GIRL

Copy of the above check is attached as Annex “C”.

3. That said checks were personally received by my staff Platinum

4. That when said checks were deposited in my bank account in

5. That a Notice of Dishonor and Demand for Payment was mailed

7. That because of the foregoing, I being the payee of said checks,

8. I am executing this affidavit to attest the truth of the foregoing

IN WITNESS WHEREOF, I have hereunto set my hand this ___

SUBSCRIBED AND SWORN to before me this_______day

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