Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Branch __________, Quezon City

PEOPLE OF THE PHILIPPINES,
Plaintiff, Crim. Case No.
______________
(I.S. No. 2005-716)
For: Estafa under Article 315
-versus- (2) (a) of the Revised
Penal Code

GAUDENCIO C. MAXIMO and
ANALIZA A. APOLTO,
(All At-large, #No. 1861 Evangelista
Street, Brgy. Pio del Pilar
Makati City)
Accused.
x---------------------------------------------x


I N F O R M A T I O N

Undersigned State Prosecutors of the Department of Justice, hereby accuse
GAUDENCIO C. MAXIMO and ANALIZA A. APOLTO of the crime of estafa under
Article 315 (2) (a) of the Revised Penal Code, committed as follows:

That on December 27, 2002, or on dates prior thereto, in Quezon
City, and within the jurisdiction of this Honorable Court, the above named
accused, being officers, employees and agents of Lead Lending
Corporation (LEAD), conspiring, confederating and mutually helping one
another, by means of false pretenses or fraudulent acts executed prior to,
or simultaneously with, the fraud, such as representing that they have the
power, qualification, property, credit and business to solicit and accept
investments from the general public and by means of other deceits of
similar import, did then and there, willfully, unlawfully and feloniously
induce, lure and convince, HECTOR T. HIPE and/or JOSE S. MOZAR,
with a promise of huge interest, to invest, give and deliver, as in fact the
latter investment, gave and delivered to the said accused the total amount
of ONE HUNDRED THOUSAND PESOS (P100, 000.00), but said
accused once in possession of the amount, fraudulently misapply,
misappropriated and converted the same, and despite repeated demands
to return the said amount and promised interests thereon failed and
refused and still fail and refused to return the same, to the damage and
prejudice of HECTOR R. HIPE and/or JOSE S. MOZAR.

CONTRARY TO LAW.

Manila for Quezon City, November 12, 2007



PRIMO P. ALONZO, II HJALMAR M. QUINTANA JR.
State Prosecutor State Prosecutor

APPROVED:


JOVENCITO R. ZUO
Chief State Prosecutor


CERTIFICATION

I hereby certify that a preliminary investigation of this case have been conducted
in accordance with law, that we have examined the complainant and its witnesses and
on the basis of the sworn statements and other evidence presented, there is reasonable
ground to believe that the offense charged have been comm9iteed and the accused are
probably guilty thereof; that the accused were informed of the complaint and of
evidence submitted against them; and that they were given an opportunity to submit
their controverting evidence.


PRIMO P. ALONZO, II
State Prosecutor

SUBSCRIBED AND SWORN to before me this _____ day of ____________ in the
City of Manila.


WITNESSES:

1. Hector T. Hipe and/or Jose S. Mozar
c/o Atty. Rico B. Bolongaita,
3264 Zapote St., Makati City
2. And others.

BAIL RECOMMENDED: FORTY THOUSAND PESOS (P30, 000.00)-EACH
ACCUSED.


ENCLOSURES:

1. Resolution dated November 12, 2007;
2. Complaint affidavit of the complainant, with enclosures; and
3. Others