Department of Finance
SECURITIES AND EXCHANGE COMMISSION
Secretariat Bldg. PICC, Pasay City
IN RE:
COMPLAINT-PETITION
ALLEGING FRAUD
INVOLVING SECURITIES,
INVESTMENT SCAM
AND “ULTRA VIRES ACT”
X=======================================================X
AFFIDAVIT- COMPLAINT
AFFIDAVIT-COMPLAINT 1
by Arrabel Queenie C. Valenzuela
She also informed that her company is just newly registered with
Securities and Exchange Commission and their business/office is located
at Unit 2804, The Milano Residences at Century City, Valdez St.
Poblacion, Makati City.
AFFIDAVIT-COMPLAINT 2
by Arrabel Queenie C. Valenzuela
checks (PDC) as payments for the agreed monthly profits in return of
investment made.
AFFIDAVIT-COMPLAINT 3
by Arrabel Queenie C. Valenzuela
10. On 12 March, 2018, I made my investment in the amount of
P250,000.00 with a promised interest of 20% per month, contract and
post-dated checks good for six months – March to September 15, 2018.
12. Lastly, On April 13, 2018, I made my investment with the total amount
of P354,880.00 with a promised interest of 20% per month, contract and
post-dated checks good for six months – April to October 15, 2018.
( so called again to be as my reinvestment due to the process of I re-
invest the last pay-outs of my ninth and tenth pay-outs (P194,880.00 and
P116,000.00 – capital plus interest) and added P44,000.00 to close it to
P354,880)
13. Wherein the above stated series of my investment made for EMMRJ,
Ms. Santos, the president of EMRRJ became deficient in paying the
monthly payments of the agreed amount of profits returns as her liability
to her company being responsible in managing and operating of its
business activities including the financial matter.
AFFIDAVIT-COMPLAINT 4
by Arrabel Queenie C. Valenzuela
14. The said deficient is due to the reason of insufficient funds of the
corporate account of EMMRJ its due date for encashment of the issued
post dated checks by Ms. Santos on the account of EMMRJ as payment
to their investors for its monthly profits return and also payment of the
refund of the total amount paid as principal investments upon maturity
date of its contract based on the executed Investment Agreement.
15. Whereas, on April 2018, Ms. Santos the president of EMMRJ made a
public announcement and/or post through the business page of EMMRJ
in her Facebook account regarding the matter on the securities of
EMMRJ and for the reasons also that the company is currently
encountering Financial problems resulting to becoming deficient in
paying the return of profits of their investors.
16. From that situation given by that time, I gave Ms. Santos the benefits of
the doubt and for giving into consideration the financial status of her
company EMMRJ, I decided to purchase the securities out of the public
offering made by Ms. Santos in the shares of stock of EMMRJ despite
also of the fact in their current status of being deficient to me on
payments of their account. Aside from my eagerness to be one of the
Directors of commitments as part owner of the company out of buying
that public offered, I also decided to purchase the shares from Ms.
Santos due to reason also that I thought my money can do a little help in
the amount that I will paid in buying the said securities of EMMRJ that
AFFIDAVIT-COMPLAINT 5
by Arrabel Queenie C. Valenzuela
can contribute to lessen the burden in the financial status of the
company by that time.
19. On July 15, 2018, I bought another 10 shares or 10% shares amounting
to P1,000,000.00 with a promised monthly profit of 20% based on the
equivalent amount given, contract, post-dated checks until I decide to
sell my shares, and perks and rewards.
20. All shares were bought due to its promising perks and rewards. No
obligations were mentioned and signed as a shareholder of the company.
21.On July 28, 2018, EMMRJ had it’s Anniversary Party in Makati. A lot
of people attended the said event. The BODs were named, financial
AFFIDAVIT-COMPLAINT 6
by Arrabel Queenie C. Valenzuela
statement was shown, future plans were mentioned and all the nearly to
be opened satellite offices.
25.On August 8, 2019 at 11:30 a.m., I went to the opening and blessing of
the Satellite Office of EMMRJ in Taguig to give support to Chief
Operating Officer (COO) Jo Mercado and also to have a word with
Elaine due to my checks that were already deposited. When I arrived at
AFFIDAVIT-COMPLAINT 7
by Arrabel Queenie C. Valenzuela
the office, Elaine had not yet arrived. I waited for almost two hours but
she informed Jo that she will be arriving late.
26.Due to my checks concerns, I opened the problem to Jo. I told her that
since the checks may be encashed on Wednesday, I deposited it Tuesday
late afternoon so it will be cleared on Thursday morning. Jo informed
me that there’s no need to be worried, since she already encashed her
checks last August 1, 2018. There’s fund in the account. But still, I told
her to inform Elaine when she arrives as I cannot wait to her any longer
due to other commitments on that day.
27.Same day at 9:08 a.m., Elaine asked me if I’ll renew my contract due on
July 30, 2018 or not. I informed her that I will be renewing on August
15, 2018 and will just add more funds. Then she messaged me
afterwards that she got a call from the bank that she had P11,000 bank
charges due to the checks that I had deposited.
28.I informed her that I brought up my concerns to Jo and to tell her the
situation. She acknowledged that my concerns had been told to her last
night as she went to the opening of satellite office in Taguig. I told her
that I was sorry and I was willing to shoulder the P11,000 bank charges.
AFFIDAVIT-COMPLAINT 8
by Arrabel Queenie C. Valenzuela
29.Elaine asked me for the breakdown of the returned checks due to DAIF
that I had deposited for counter-checking and which bank. I told her that
the checks amounted to P160,000, P120,000 and P684,000 respectively
which I had deposited to my PSBank account.
30.I informed her that I will get the returned checks on that day as the bank
already called me.
31.At 2:44 p.m., Elaine messaged me that the funds in BDO had not yet
cleared. I asked her what time can I encashed the checks. She informed
that the clearing usual time was 3 p.m. and she will notice me asap once
okay.
32.At 4:02 p.m., Elaine messaged me again that she just checked with the
bank that it was not yet cleared. It will be 12 noon tomorrow if it will be
cleared today.
33.On August 10, 2018 at 3:30 p.m., I went to BDO in Makati to encash the
three checks. At 3:36 p.m., Elaine texted me, “Hello, got a call from bdo
that you are encashing your checks. But our funds isn’t cleared yet. You
may deposit the 120k and 160k yata yun as it will cover our maintaining
pero the other check po pa undergo mo na lang daw ng 1 day clearing.
Baka kasi mamaya pa daw pumasok clearing naming.”
AFFIDAVIT-COMPLAINT 9
by Arrabel Queenie C. Valenzuela
34.In return, I verified her text and told her that I will on-us the two checks
120k and 160k and the other check 684k will be for late deposit which
she acknowledged.
35.On August 12, 2018 at 4:17 p.m., Elaine sent a message to all the
directors and attached a document report about the current situation of
the company and challenges with the call centers. Elaine asked for
possible solutions or suggestions since the call centers stated on the
document have a lot of pending borrowers which need to be addressed
immediately.
36.On August 12, 2018 around 5:30 p.m., Elaine posted a memo due to
current challenges with call centers most of the directors suggested to
have a force re-investment for the months of July and August so the
company can cope with the amount needed. I was not able to make a
suggestion on that day as I had seen the message late.
37.On August 14, 2018 at 3:12 p.m., I messaged Elaine and apologized for
not making a comment or suggestion about the situation. But since there
was already a solution made for the current situation, I just agree with it.
Then I informed her that the check that she asked me to do late deposit
bounced for the second time. I told her that the penalty made on the first
return will be paid on my September pay-out. I also asked her, how
AFFIDAVIT-COMPLAINT 10
by Arrabel Queenie C. Valenzuela
much will be the rate for re-investment. She acknowledged the bounced
check and informed that the rate will be 20%.
38.On August 16, 2018 at 4:48 p.m., I messaged Elaine in FB and asked her
about the pending pay-outs for the months of July and August. When
will be the start of counting for the interest? Will it start on the 20 th of
September or will the missed months – August 5, 20 and September 5 be
counted also? I told her that these were my insights as there will be
confusions and there will be a lot of expectations.
40.To clarify her answers, I asked her if there will be months that won’t
have interest since the resume of pay-out will be on the 20th of
September. She answered that it will still have interest but it will be
reinvested.
AFFIDAVIT-COMPLAINT 11
by Arrabel Queenie C. Valenzuela
asking for a CA and is subject for closure due to lack of Secondary
License and will be reopened once complete requirements. For the mean
time options that we can use is direct deposit for pay-outs and helping
hands and other businesses bank accounts for investments. We will have
to comply with the SEC penalty for additional shares (75) 44 taken and
31 more to go for the release of our CA. Once complied release will only
take less than a week.”
42.On September 3, 2018 at 7:58 p.m., I messaged Elaine if I can send my
computation for her to counter check if we are tally. It was for the
preparation of September 20th pay-out.
AFFIDAVIT-COMPLAINT 12
by Arrabel Queenie C. Valenzuela
47.On September 14, 2018 at 3:59 p.m., I made a follow-up again to Elaine
if we were tallied and told her that if it was already ok, I will drop by
next week to get the new contracts.
49.I answered her that I hope she already feels better and to rest well.
50.On September 19, 2018 at 12:14 p.m., I messaged Elaine that I hope she
was already fine. I asked her if we were already tallied as I will be in
Makati the next day where I can drop by to get the new contracts and
give the checks for replacement. I hope that her schedule was ok as I
want to discuss her something as well.
51.At 3:31 p.m., she informed that she was in SEC and will read the
messages later.
52.At 7:35 p.m., she sent a picture of hers holding the Secondary License
from SEC where I congratulated her in return.
AFFIDAVIT-COMPLAINT 13
by Arrabel Queenie C. Valenzuela
53.On September 20, 2018 at 1:29 p.m., I messaged her that I will be going
to the office at late afternoon. She answered me to drop by the following
day as they were fixing the re-instatement of bank accounts of EMMRJ.
55.On September 21, 2018 at 11:21 a.m., I messaged Elaine and asked if
she’ll be in the office the whole afternoon. She informed that she already
went out. So I asked her if I can just call her and I want to ask some
questions. She told me to call her at night.
56.At 8:08 p.m., I messaged Elaine if it’s already ok to call her. She sent me
a picture inside a hospital room and told me to wait and she was at
Makati Medical Center Hospital.
57.At 9:28 p.m. I messaged Elaine again in FB messenger and asked you
the following:
AFFIDAVIT-COMPLAINT 14
by Arrabel Queenie C. Valenzuela
“Hi Elaine, good pm! Nakita ko yung pix mo. I know na naiistress
ka na rin katulad ko. Ano ba maitutulong ko syo para malessen naman
ung stress mo? Pero need ko rin malaman kung nangyayari talaga kasi
nahihirapan na rin kasi ako mag-abono. Ayokong masira ung company
natin kaya ginagawa ko rin yun. Syempre hindi nila maiintindihan un
pag wala tayong pay-out. Magtulungan tayo to lessen each other’s stress.
I’m very much willing to help. Ito lang din naman ung concerns ko at ng
mga downlines ko.
58.Sana makakuha ako ng sagot syo para ung sasabihin mo un din ang
sasabihin ko sa mga tao, para hindi sila mag-alala.
59.I’m very much willing to help basta alam ko ung direction natin. Alam
mo naman, loyalista mo ko kahit di pa tayo registered. Get well soon.
AFFIDAVIT-COMPLAINT 15
by Arrabel Queenie C. Valenzuela
60.The only answer that I got from her was “Sagutin po kita once okay na
ako ha.”
61.On September 24, 2018, I went to the office at 817 J.P Rizal St. Makati
City around 1:00 p.m., Elaine was not there. Mylene, her niece and
assistant, called Elaine over the phone informed that I am in the office
and I wanted to talk to her.
62.I asked Elaine the same questions that I sent to her in FB messenger last
September 21, 2018. And these were her answers about my concerns:
1. The pay-out will be within the week (September 25 to 28, 2018) once
the accounts have been reinstated and the checks that I have can be
used for encashment.
2. The counting of force reinvestment will start on the 20 th of October
2018. New contracts will be released and the interest will be the
same.
AFFIDAVIT-COMPLAINT 16
by Arrabel Queenie C. Valenzuela
3. Elaine informed that there will be no problem even if the September
20th and October 5th pay-outs were nearly contiguous.
63.The following day, September 25, 2018 at 3:17 p.m., I messaged Elaine
in FB asking for an update regarding the reinstatement of the account. I
informed her that me and my family will have an out of town trip to
celebrate my birthday the following day. I will just ask my sister to
deposit the checks in my account, and also to update my riders.
64.Elaine informed, “As of now wala pa. Antay lang ng approval po.
Inform kita later.”
On September 26, 2018 at 8:00 a.m., I sent Elaine messages in
FB, asking her again for an update regarding the status of reinstatement,
if we were already okay with BSP, if we were just waiting the Head
Office (BDO) and how many days will it take according to the branch of
account?
65.On September 27, 2018 at 7:02 p.m., I messaged Elaine again asking if
the account was already ok and if the checks can be encashed already.
66.Instead, Elaine just sent me a memo that had been posted on the page of
the company stating the following:
AFFIDAVIT-COMPLAINT 17
by Arrabel Queenie C. Valenzuela
1. All Pay-outs for Sept. 20th are still pending due to suspension of bank
accounts especially our Chinabank (SEC Advisory).
2. Secondary License or Certificate of Authority has been released
already since last week.
3. Registration Permit as Investment Firm is still pending at CGFD SEC
Main Office Pasay.
4. 1 Bank Account of EMMRJ has been reinstated while others are still
for approval.
5. We are still waiting for EMMRJ Bank Clearance so we can transact.
6. Expected time to complete this clearance is around 3 banking days
depends on the release of the clearance.
7. Branch of Account already sent a follow up with their head office.
8. Petition to remove SEC Advisory was also filed at the SEC Main
Office.
9. Investors may still opt to pull-out within 180 banking days return of
capital. Letter of Intent to pull-out must be submitted to process and
start counting the 180 days for the return.
67.This was the first memo that she released to give us an update. Several
memos were posted afterwards but there was no clear date when will be
the pay-out.
68.On October 22, 2018 at 4:30 p.m. me and my partner went to the office.
Elaine was in the office. I asked her the updates of the company. She
AFFIDAVIT-COMPLAINT 18
by Arrabel Queenie C. Valenzuela
informed us the status of the company and where it was heading. She
informed that hopefully by 2nd week of November all will be well.
70.Email had been sent and I asked her if she could give me P100,000.00
per week until the operation of the company normalized. She
acknowledged my email and informed me that she’ll give an update.
Two weeks after she informed that she could only give P100,000.00
which she’ll withdraw from their stocks of her husband. I waited and
sent her several e-mails and text messages but got no reply from her
anymore after that. She was not even answering my calls.
71.Months passed, on December 11, 2018, Elaine posted updates that the
company already opened an account with Security Bank and they had
already ordered checks for the replacement of Metrobank and Chinabank
checks, replacement of checks will start as soon as they receive the new
PDCs from the new accounts and collection will resume that week once
the account restriction has been removed. She also informed that the
details of the new bank account had already been provided to the BPO
AFFIDAVIT-COMPLAINT 19
by Arrabel Queenie C. Valenzuela
companies, and subject for approval and enrollment of their Accounting
Departments.
72.From December 11 to 14, 2018 updates, all were the same except on
December 14, 2018 wherein Elaine informed that the collection will be
ready for bank transfer and the bank account had been reactivated.
73.On December 17, 2018, new updates were released. Elaine informed that
the collection had already started that night and pay-outs will be bank
deposits for now. She asked us to provide our bank details and amount
of pay-out for counter checking and records.
74.On December 18, 2018, I sent Elaine via excel file all the pending
checks that are due. I informed her that I don’t know if she’ll give
interest on those pending so I sent it which she acknowledged it after
sending.
75.On December 19, 2018, new updates had been given wherein the
collection progress was already at 20% and the final schedule of pay-
outs will be released the following day, December 20, 2018.
76.On December 20, 2018, new updates were given. The collection
progress was already at 25 to 30%, the December 20th pay-outs will be
deposited the following day, December 21, 2018, with an open and close
AFFIDAVIT-COMPLAINT 20
by Arrabel Queenie C. Valenzuela
parentheses – whichever is the amount collected some will be distributed
to investors and some to borrowers and backlogs/missed pay-outs will
be given upon completion of collections.
77.On December 21, 2018, again new updates were given. The collection
progress was already at 30 to 35%, they already started to deposit pay-
outs for December 20th dues which will be continued on the 27th of 78.
December and schedules of backlogs will be released upon completion
of collections.
78.On December 27, 2018, the updates were the same. Collections were at
35% and the pay-outs were on-going.
79.From December 20th onwards, all business days, I had been checking my
BDO account if any amount had been credited to my account since
Elaine informed that the pay-outs will be through bank deposit first.
80.On January 4, 2019, all updates were still the same. Collections were
already at 40% and the pay-outs were still on-going which will be
continued on Monday. The progress update about the Security Bank
checks had been removed.
AFFIDAVIT-COMPLAINT 21
by Arrabel Queenie C. Valenzuela
81.The same day at 11:02 p.m, I made a follow-up regarding the pay-out –
process and amount of percentage that will paid. She only answered me
that pay-outs are being paid via surname and I was scheduled on January
9, 2019. The amount of percentage had not been answered. The
promised date came but I did not receive any pay-out on that day.
82.On January 15, 2019, I went to the office in J.P Rizal at 4:10 p.m. for me
to follow-up my pay-out and to ask for the replacement of my checks
since it is nearly to be expired. Unfortunately, the office was closed. So I
asked the nearby establishment if the office of EMMRJ is still operating,
I was informed that it is still opening but the office hours had been
shortened. People in the office were leaving around 3:30 p.m.
83.From December 19, 2018 up to January 15, 2019, the collection progress
went up till 50% and still even a single cent had not been deposited in
my bank account. Elaine just informed us to be patient with the process
as it takes some time because of the bank requirement. That’s why they
cannot process all in one time.
84.On January 18, 2019, I sent two same letters to Elaine addressed in The
Milano Residence and in J.P Rizal via registered mail informing her that
I had already deposited all the pending checks that she issued to me, I
cannot see any sincerity and assurance that she’ll do the promises that
she said where I have already given her enough time and have made
AFFIDAVIT-COMPLAINT 22
by Arrabel Queenie C. Valenzuela
bargains as well but nothing prospered. And with this, I am resigning
and withdrawing all of my shares and investments as a Board of
Director/ Shareholder and as an investor effective immediately.
85.On January 21, 2019, I went to PSBank to check the status of the checks
that I had deposited. Unfortunately, all the 34 checks deposited bounced
due to closed account.
86.On that day, I did my researched. I was able to know that the checking
account in BDO had been closed since November 2018 and there was no
such term as reinstatement of bank account. It was either closed or
active. And the bank won’t allow a company to open a corporate account
without having complete business papers and permits.
87.On January 28, 2019, demand letters were sent to Elaine addressed in
Milano and in J.P Rizal offices via registered mail and hand-carry. I got
to know on the same day via post that the office hours in J.P Rizal had
been shortened and changed, it is operating from Monday to Friday 7
a.m. to 2 p.m.
Listed below all the checks that I had deposited and bounced due to DAIF and
closed account.:
AFFIDAVIT-COMPLAINT 23
by Arrabel Queenie C. Valenzuela
1 July 30, 2018 BDO 1019355
684,000.00
2 August 15, 2018 Chinabank 19360
70,976.00
3 August 15, 2018 BDO 1019385
180,000.00
4 August 15, 2018 BDO 1034537
50,000.00
5 August 15, 2018 BDO 1048246
78,000.00
6 August 15, 2018 BDO 104172
120,000.00
7 August 15, 2018 BDO 1062718
75,000.00
8 August 30, 2018 BDO 1034723
80,000.00
9 August 30, 2018 BDO 1048033
120,000.00
10 August 30, 2018 BDO 1034416
360,000.00
11 September 5, 2018 BDO 1062707
160,000.00
12 September 15, 2018 BDO 1048173
120,000.00
AFFIDAVIT-COMPLAINT 24
by Arrabel Queenie C. Valenzuela
13 September 15, 2018 BDO 1034538
300,000.00
14 September 15, 2018 BDO 1048247
78,000.00
15 September 15, 2018 Chinabank 19361
70,976.00
16 September 20, 2018 BDO 1062719
75,000.00
17 September 30, 2018 BDO 1048034
120,000.00
18 September 30, 2018 BDO 1034724
480,000.00
19 October 5, 2018 BDO 1062708 160,000.00
20 October 15, 2018 Chinabank 19362
425,856.00
21 October 15, 2018 BDO 1048174
120,000.00
22 October 15, 2018 BDO 1048248
78,000.00
23 October 20, 2018 BDO 1062720
75,000.00
24 October 30, 2018 BDO 1048035
120,000.00
25 November 5, 2018 BDO 1062709
AFFIDAVIT-COMPLAINT 25
by Arrabel Queenie C. Valenzuela
160,000.00
26 November 15, 2018 BDO 1048175
120,000.00
27 November 15, 2018 BDO 1048250
468,000.00
28 November 20, 2018 BDO 1062721
75,000.00
29 December 5, 2018 BDO 1048036
120,000.00
30 December 5, 2018 BDO 1062710
160,000.00
31 December 15, 2018 BDO 1048176
120,000.00
32 December 20, 2018 BDO 1062722 75,000.00
33 December 30, 2018 BDO 1048037 120,000.00
34 January 5, 2019 BDO 1062711 160,000.00
35 January 15, 2019 BDO 1048177 120,000.00
88. In connection to the above listed checks, which I had deposited and
bounced due to DAIF and closed account, there is still 21 checks
remaining on my possession that I have not included in the pending
case filed for Estafa and B.P. 22 with the Makati City Prosecutors
Office amounting to P2,445,000.00 which I am also about to filed in
AFFIDAVIT-COMPLAINT 26
by Arrabel Queenie C. Valenzuela
addition to the said pending case for same criminal case, which details
of said remaining checks are listed hereunder:
Listed below are all the checks that remaining that I am about to file with same
case for Estafa and B.P. 22 in addition to the earlier said case filed with Makati
City Prosecutors Office for inclusion to the computation of the damages demanded
to be paid by EMMRJ LOAN CONSULTANCY CORPORATION through its
President Ms. Elaine Joy Santos.
Date Bank Check No. Amount
1 January 20, 2019 BDO 1062723 75,000.00
2 January 30, 2019 BDO 1062724 75,000.00
3 February 5, 2019 BDO 1062725 75,000.00
4 February 15, 2019 BDO 1062726 75,000.00
5 February 20, 2019 BDO 1062727 75,000.00
6 February 28, 2019 BDO 1048038 120,000.00
7 March 5, 2019 BDO 1048039 120,000.00
8 March 15, 2019 BDO 1048040 120,000.00
9 March 20, 2019 BDO 1048041 12 0,000.00
10 March 30, 2019 BDO 1048178 120,000.00
11 April 5, 2019 BDO 1048179 120,000.00
12 April 15, 2019 BDO 1048180 120,000.00
13 April 20, 2019 BDO 1048181 120,000.00
14 April 30,2019 BDO 1062712 160,000.00
AFFIDAVIT-COMPLAINT 27
by Arrabel Queenie C. Valenzuela
15 May 15, 2019 BDO 1062713 160,000.00
16 May 15, 2019 BDO 1062714 160,000.00
17 May 20, 2019 BDO 1062715 160,000.00
18 June 5, 2019 BDO 1062716 160,000.00
19 July 5, 2019 BDO 1062717 160,000.00
20 June 20, 2019 BDO 1062728 75,000.00
21 July 30, 2019 BDO 1062729 75,000.00
89. Despite of repeated Demands in Six (6) consecutive times sent via
registered mails and personal mails/delivery, up to this moment no effort
has been made from Ms. Elaine Joy Santos being the President as
responsible for all the operations and management of the business
activities and/or from any of its Directors /Stockholders of EMMRJ
Loan Consultancy Corporation to contact me regarding the above cited
demands.
AFFIDAVIT-COMPLAINT 28
by Arrabel Queenie C. Valenzuela
her wrongful acts on the matter of its business commitments and
obligations .
91. The above said criminal case was filed on April 17, 2019 before the
Makati City Office of Prosecutor by my legal counsel for and in behalf
of me against Elaine Joy Santos with docket /Case No. XV-05-
INV191481.
92. On the dates set by court for explanation and preliminary hearing on
May 23 2019 and May 30, 2019 were both unattended by Ms. Elaine Joy
Santos despite of the summons sent by clerk of court at Makati City
Office of Prosecutor to her office address.
93. The unlawful acts of Ms. Santos caused great loss and damages to me
in the amount I paid for investments amounting to P2,414,000.00 and in
the amount I paid for securities I purchased in 20 shares amounting to
2,000,000.00 and also in the amount that I spent in filing the instant case
through my counsel amounting to 250,000.00 including his attorney’s
fees and also the amount of my unpaid profits and income plus the
accumulating penalties of it.
94. And in continuance of Ms. Santos unlawful acts on the account of her
company EMMRJ LOAN CONSULTANCY CORPORATION is the
great discovery of fraud transactions in securities and investment
contracts due to the wrongfully act of its President Elaine Joy Santos in
fraud reporting and fraud transactions on its business ventures as
AFFIDAVIT-COMPLAINT 29
by Arrabel Queenie C. Valenzuela
Investment Company, Lending Company resulting to Serious
Misrepresentation on part EMMRJ and committing Ultra Vires Act on
the account of Ms. Santos as held to be liable.
AFFIDAVIT-COMPLAINT 31
by Arrabel Queenie C. Valenzuela