Complaint-Affidavit Carnapping

Republic of the Philipines )
Bacoor City, Cavite ) s.s.

x---------------------------------------------------x
COMPLAINT-AFFIDAVIT
I, CECILIA T. DE GUZMAN, of legal age, residing in 69 C. Maliksi 1, Bacoor City,

Cavite, do hereby allege the following statements in support of my complaint-affidavit:
1. In the year 2017, I purchased a vehicle at Toyota Bacoor Branch on an

installment basis where such vehicle has the following details:
Vehicle Make: Toyota

Variant: Vios 1.3 E Gas A/T
Year: 2017
Body Color: Orange Metallic
Conduction Sticker: WA 6942
Engine No.: 1NRX163377
Chassis No.: PA1B19F35H4032687
2. The said purchase on installment basis will be for five (5) years, commencing on
2017 until 2022 for Sixteen Thousand Pesos or P16,000.00 due each month in
favor of Toyota Financial Services Philippines Corporation (TFSPC);
3. My obligations with TFSPC from 01 August 2017 to 01 June 2019 were satisfied
either by me personally or by some other person who will be referred to in the
immediately preceding paragraph;
4. Sometime in the year 2018, my husband suffered a medical condition which put
a burden on my finances. To alleviate my situation, I confided my friend Vangie
Monson who, as a result, shared my concerns to her cousin Mr. Tristan Monson
Lacuerta;
5. Mr. Lacuerta agreed to pay me Thirty Thousand Pesos or P30,000.00 in

exchange for the vehicle’s physical possession and care to be transferred to him.
The same amount was used to pay the monthly installment for April and May
2019;
6. I requested Mr. Lacuerta to continue paying for the monthly installments in favor
of TFSPC and start adding a small amount in my favor so that I would be able to
recover the initial payments I previously made to TFSPC which totalled at Eighty-
Four Thousand Pesos or P84, 000.00.
7. Mr. Lacuerta paid the monthly installment for June 2019;

8. Sometime during May 2019, I met and befriended a lady named Ms. ELLIZZA R.
TUAZON and her common-law spouse Mr. RENZ PLAZA, both residing in Blk. 5
Lot 8 Metrogate, Silang, Cavite, Philippines;
9. I intimated to Ms. Tuazon that my vehicle is under the care and possession of Mr.
Lacuerta;
10. It was when Ms. Tuazon said that she will instead take possession of the said
vehicle from Mr. Lacuerta, with my permission, where she will be the one who will
pay the monthly installments to help me in my daily subsistence;
11. After much convincing, I transferred the care and possession of the said vehicle
to Ms. Tuazon, under the representation that she will pay the monthly
installments, add a sum for my benefit, and/or pay the full amount of the vehicle
in cash;
12. To formalize our agreement to transfer the possession of the said vehicle to Ms.
Tuazon, we executed a document entitled “KASUNDUAN” on 01 July 2019
hereto attached as Annex “A”;
13. On July 2019, I told Ms. Tuazon to pay the monthly installment due for that
month. While she was able to pay the same, a penalty was incurred thereon. The
same was paid by Ms. Tuazon;
14. On August 2019, I reminded her of the monthly installment due for that month;
15. On September 2019, a notice was sent by TFSPC to me indicating that I should
comply with my financial obligation. Otherwise, the vehicle will be repossessed
by TFSPC;
16. Around the same time, Ms. Tuazon came to my residence, nearing midnight,
asking for my driver’s license, the vehicle’s official receipt (OR), and certificate of
registration (CR) issued by the Land Transportation Office (LTO) stating that she
needs them;
17. Ms. Tuazon stated that she will pawn the vehicle to Toyota Bacoor branch but
will redeem the same within seven (7) days. I did not agree to the same;
18. On the succeeding months until November 2019, I was not able to contact her at
all;
19. On 07 November 2019, TFSPC sent me a Notice of Legal Action;
20. On 20 November 2019, I went to her residence but was instructed by the guard
not to proceed since the vehicle, according to the guard, is not anymore in the
possession of Ms. Tuazon;
21. I immediately went to the Barangay Hall having jurisdiction over the area where
Ms. Tuazon is residing and filed a complaint therein;
22. A hearing was scheduled on 23 November 2019, 10:00 AM;
23. The day before the said date, Ms. Tuazon and Mr. Plaza went to my house and
attempted to make a settlement, stating that they will pay all the unpaid
installments with penalties on the 30th of November in exchange of dropping the
complaint before the Barangay;
24. No payment was made on the said date and no return of the vehicle was also
made;
25. Until the date of executing this complaint-affidavit, the vehicle is still nowhere to
be found and has not yet been returned by Ms. Tuazon upon my consistent
demands for its return;
I am therefore executing this Complaint-Affidavit in support of the charge for violation of

Republic Act No. 10883 otherwise known as the “New Anti-Carnapping Act of 2016”
against Ms. ELLIZZA R. TUAZON, who may be served with subpoena and other legal
processes of this Honorable Office at her address Blk. 5 Lot 8 Metrogate, Silang,
Cavite, Philippines;
IN WITNESS WHEREOF, I have hereunto set my hand this ___________ at

___________, Philippines.

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Republic of the Philipines )

Bacoor City, Cavite ) s.s.

I, CECILIA T. DE GUZMAN, of legal age, residing in 69 C. Maliksi 1, Bacoor City,

1. In the year 2017, I purchased a vehicle at Toyota Bacoor Branch on an

Vehicle Make: Toyota

5. Mr. Lacuerta agreed to pay me Thirty Thousand Pesos or P30,000.00 in

7. Mr. Lacuerta paid the monthly installment for June 2019;

19. On 07 November 2019, TFSPC sent me a Notice of Legal Action;

22. A hearing was scheduled on 23 November 2019, 10:00 AM;

I am therefore executing this Complaint-Affidavit in support of the charge for violation of

IN WITNESS WHEREOF, I have hereunto set my hand this ___________ at

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