REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN CITIES

ILOILO CITY
BRANCH 5

THE PEOPLE OF THE PHILIPPINES CRIM. CASE NO. R-14-10

FOR: FALSIFICATION OF
-VERSUS- COMMERCIAL DOCUMENT

PAULA ARINQUIN PAJA (a.k.a)

MA. PETRA PAULA FUERTE ARINQUIN
Accused (Bonded)
x-----------------------------------------------------------x

FORMAL OFFER OF EVIDENCE

FOR THE PROSECUTION

PRIVATE COMPLAINANT by the undersigned acting Iloilo City Prosecutor, and to

this Honorable Court formally offer the following marked exhibits of the Prosecution in wit:

EXHIBITS: DESCRIPTION : PURPOSES

A Complaint Affidavit
of Marilyn Andaya
with annexes consist-
ing of four (4) pages
1) To prove that said accused Paula Arinquin, et. al.
falsified the signatures of Salvador Paja I in
PBCOM withdrawal slip dated Jan. 3, 2005 while
Atty. Salvador Paja are in the U.S.A. hospital
suffering serious illness and bedridden. The said
accused used not valid documents to withdraw the
amount of Php 1,159,198.11 of Paja Development
Corporation Savings Account No. 293-20-000485-7 at
PBCom Iloilo Branch, Iloilo City and she (accused)
closed the said P.D. Corp. Savings Account unknown
from Paja Development Corporation. Even both not
authorized and accused never remit the said Php
1,159,198.11 to said Paja Development Corp. instead
accused used for her own personal use and benefits and
damage and prejudice Paja Development Corporation of
the said amount etc.

a) Also, to prove that the following Paja Development

Corporation Resolutions: No. 001 Series of 2008,
which appointed and authorized Marilyn Andaya
and/or Pilar Alarcon Paja to take all appropriate
legal action, whether criminal or civil or
administrative, etc. action in behalf of the PD Corp.
Also stating among others that it was discovered that
certain persons are disposing of or have already
disposed of corporate properties, withdrawn
corporate funds and closed corporate bank accounts,
closed Safety Box Deposit, and closed Checking
Account No. 02-93-239-8 of PD Corp. and/or
Salvador Paja I at PB Com. Iloilo Branch and which
said PD Corp. Resolution No. 001 Series of 2008,
adap the Paja Devt. Corp. Resolution dated Dec.
15,2010 signed by the new PD Corp. new corporate
secretary Filipina Bunda, to adap in all respect the
previous PD Corp. Board Resolution No. 001 Series
of 2008, of the same.
b) The American Doctors Certification that Atty.
Salvador Paja I suffering in major strokes from
about May 2004 and confined, bedridden in the
hospital at America for several years.
c) That while Atty. Paja was suffering major stroke
confined in the hospital in L.A. U.S.A. which
authenticated before Consulate General of the
Philippines at L.A., U.S.A. ;
d) To prove that Los Angeles, USA. Superior Court
Order in Case No. BP-089-201 appointed Mr. Stan
Mandell as Temporary Guardianship or
conservatorship for the state of Salvador Paja I.

f) To prove that Los Angeles Superior Court in Case
ALL POWER OF ATTORNEY SALVADOR PAJA I ARE REVOKED
of the said superior court dated June 9, 2005
g) That to prove that said L.A., USA Court issued an
B Specimen signature and 1. To prove that the authorized representative
authorized representative
of Paja Development Corp-
oration of its corporate ac-
counts with Paja Devt.
Corporation Information
C Withdrawal Slip
D Durable General Power
Durable
of Attorney
E Certification/Resolution
e) That to prove said temporary guardian for Salvador
Paja I of Los Angeles Superior Court was
authenticated before Consulate General of the
Philippines, City of Los Angeles, USA signed by
Noemi T. Diaz as Vice Consulate of the said
Consulate General.
No. BP-089-202 the court order stated that:
Signed by Honorable Aviva K. Bobb, the judge
ORDER that all powers of Attorney by Salvador
Paja I are revoked and was not authenticated before
Consulate General of the Philippines signed by ;
of PD Corporation of its corporate accounts with
PBCom, Iloilo Branch are Salvador Paja I and
Marilyn Andaya only, the accused Paula mistress
of Salvador Paja I is not authorized representative
of Paja Development Corporation and never been
stockholder of the said P.D. Corporation who pleaded
guilty in criminal case of concubinage, Court Order
The signature of Salvador Paja I appearing in this
original Exhibit B is true and can be used one of
standard signature of one Salvador Paja I or
comparison/examination to determine whether or
not the falsified signature of Salvador Paja I
appearing on PBCom falsified withdrawal slip dated
Jan. 3, 2005 used to withdraw Php 1,159,198.11
from Paja Development Corp. even without PD
Corp. Board Resolution are contrary to law
1. To prove that accused alias Paula Arinquin Paja
fabricated falsified the signature of Salvador Paja I,
dated Jan. 3, 2005 while Salvador Paja I was
bedridden, comatose confined in the hospital at
America since about May 2004 suffering major
strokes and serious illness.
1. To prove the illegal fabricated engineered
General power appearing the falsified signature
of Salvador Paja I. Even granting but not
admitting, still not valid document in the Philippines
for not authenticated before Consulate General of
the Philippines at USA etc.
1. To prove that Paja Development Corporation
Resolution No. 001 Series of 2008
appointed and authorized Marilyn Andaya and/or
Pilar Alarcon Paja to take all appropriate legal
action, whether criminal or civil, or administrative,
etc. action in behalf of the PD Corp. Also stating
among others, that it was discovered that certain
persons are disposing of or have already disposed
of corporate properties, withdrawn corporate funds
and closed corporate bank accounts, closed Safety
Box Deposit and closed Checking Account No.
02-93-239-8 etc. of PD Corporation and/or
Salvador Paja I at PBCom Iloilo Branch and which
said PD Corp. Resolution No. 001 Series of 2008
adap the Paja Development Corp. Resolution
dated Dec. 13, 2010
F Affidavit of Pilar 1. To prove that Ma. Petra Paula Fuerte Arinquin
alias
Alarcon Paja Paula Arinquin Paja falsified commercial
documents/withdrawal slip of PBCom and falsified
the signature of Atty. Salvador Paja I appearing in
the said PBCom withdrawal Slip used by her
withdrawal of Php 1,159,198.11 from the Paja
Development Corp. Savings Account No. 293-20-
000485-7 at PBCom. Iloilo Branch Iloilo City and
said accused also illegally closed the said Paja
Devt. Corp. Savings Account without any legal
document and any authority, no Paja Dev. Corp.
Board Resolution and never remit the said Php
1,159,198.11 to said PD Corp. instead accused used
the said money for her own personal use and
benefits and damage and prejudice, Paja
Development Corporation of the said amounts. The
said accused mistress of my legal husband alias
Paula Arinquin Paja also closed the Safety Box
Deposit and also clode and withdrawn funds and
also closed the checking Account No. 0293239-8 o
Paja Development Corp. and/or Salvador Paja I at
PBCom Iloilo Branch, Iloilo City.

2. On January 03, 2005 when accused withdrawn

P1m pesos and closed the said Paja Devt. Savings
Account, while Atty. Salvador Paja I are suffering
major stroke and serious illness bedridden and
confined at L.A. US hospital since about May 2004
until several years .
3. To prove that the original copies of all the
documents used by accused to illegally withdraw
P1,159,198.11 and her illegal closing the said Paja
Devt Corp. Savings Account are in possession of
PBCom Iloilo Branch, Iloilo City including but
limited to the followings:
A) the said Withdrawal Slip of PBCom which was
used by accused on January 03, 2005to her illegal
withdrawal of one(1) million plus and her illegal
closing of the said Paja Devt Corporation Savings
Account.
B) The said original copy of the information, the
signatures of the officers of the Paja Devt Corp.
authorized to sign or the said Corporation or
specimen signatures and authorized representative
of Paja Devt. Corporation of its corporate accounts
with PD Corporation Information.
C) The original copy of the said Durable General
Power of Attorney allegedly signed by Atty.
Salvador Paja I.
D) The original copies of all other documents
/papers and/or records used while accused alias
Paula Arinquin Paja withdrawn the said
P1,159,198.11 and allowed to closed the Paja
Development Corporation Savings Account even
without P.D. Corporation Resolution and no
authority from P.D. Corporation.

G Judicial Affidavit
Executed by PD Corp.
Corporate secretary
Filipina Bunda 1) To prove that Paja Development Corporation
Resolution dated December 15, 2010 was been
ADAP in all respect the previous Paja
Development Corporation Board Resolution No.
001, series of 2008 for the continuing protections
and presentations of the corporate assets and Bank
deposits etc. to file institute the necessary actions
etc, whether criminal, civil, administrative, etc, to
 protect the interests of Paja Dev. Corp. in all the
proceedings signed by the new secretary Filipina
Bunda.
2) She testified that she knows Marilyn Andaya the
corporate treasurer of Paja Development Corp. and
also the authorized representative to file complaints
against the accused which is the subject matter in
this case.
3) Also to prove that P.D. Corporation corporate
secretary Filipina Bunda presented proof copy of
Paja Devt. Corporation Board Resolution No. 001,
Series o 2008, or appointed Marilyn Andaya and/or
Pilar Alarcon Paja for authorized to take all
appropriate legal actions, whether criminal or civil,
administrative, etc. action in behalf of the
corporation also stating among others that it was
discovered that certain persons are disposing of or
have already disposed of corporate properties,
withdrawn corporate funds and closed corporate
bank accounts etc., amount, and taken all contain
and their safety box and bank accounts, etc. of Paja
Devt. Corporation and/or Atty. Salvador Paja I at
PBCom Iloilo Branch, Iloilo City and which has
been adap by P.D. Corporation Resolution dated
December 15, 2010 signed by corporate Secretary
Filipina Bunda. Etc.

H Judicial affidavit
Executed by Brayan
Christopher Tan Ong
Authorized representative
Of PBCOM Iloilo Branch
Iloilo City 1) To prove that all the several original documents,
records, etc., used by PBCom Iloilo Branch which
accused Paula Arinquin Paja allowed to withdrawn
the amount of P1,159,198.11 from Paja
Development Corporation and allowed to closed
the Paja Devt. Corporation Savings Account No.
293-20-000485-7 on January 03, 2005. are in
possession of the said PBCom Iloilo Branch, Iloilo
City.
2) To prove that the some of the several original
documents are the followings:
a) The original copy of the Withdrawal Slip from
PBCom dated January 03, 2005.
b) The original Copy of the signaturecard of Paja
Development Corporation dated April 23, 1996
under account No. 293-20-000485-7

I Certification from office

Of the Mayor, Iloilo City
Dated May 1996 showing
The original structure of
Salvador Paja I (annex) 1. To show the true signature of Atty. Salvador Paja
I wherein are differences in handwriting
characteristics, habits, strokes between the question
signature appearing in illegal Withdrawal Slip
allegedly signature by Atty. Salvador Paja I.
J Certified true photo copy of Philippine
Passport No. LL874061 o Salvador Paja I
Issued by the NBI chief of the Questioned
Documents Laboratory Division at Taft,
Manila. Because the original copy of the
Said Philippine Passport o the said Salvador
Paja I, is in the possession of the NBI, which
Submitted by the undersigned in relation
To her requesting the said NBI handwriting
Examination of the question signature of
Salvador Paja I, to determine whether or not
The questioned signatures of one Salvador
Paja I. To prove that Atty. Salvador Paja I is a Filipino
citizen, a holder of Philippine Passport No.
LL874061 that the nationality is Filipino as
indicated in the said passport