Republic of the Philippines

Department of Justice
OFFICE OF THE CITY PROSECUTOR
Quezon City

XXXXXXXXX
Complainant,
I.S. No. _____________________
For: ESTAFA with ABUSE OF
CONFIDENCE

- versus -

(Article 315 paragraph 1(b) of the

Revised Penal Code, as amended)

XXXXXXXXX,
Respondent.
x-----------------------------------------------------------------------------------------------------------------x
COMPLAINT-AFFIDAVIT
I, XXXXXXXXX, Filipino, married of legal age, and with business address at care
of xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx, after having been sworn to in accordance with
law, do hereby depose and state that:
1.

I am currently employed with xxxxxxxxxxxx as the xxxxxxxxxxxxxxxxxxxxxxxx,

which position I have been holding since xxxxxxxx up to the present.
xxxxxxxxxxxxxxxxxxxxxxxx is a corporation duly organized and existing under,
and by virtue of, the laws of the Philippines, and with principal offices at the
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx, Quezon City.
xxxxxxxxxxxx is
xxxxxxxxxxxxxxxxx
engaged
in
the
business
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx .

2.

I have been duly authorized to file this complaint by the Board of Directors of
xxxxxxxxxxxxxxxxx against XXXXXXXXXXXXXXXXXXXXX, who may be served
with subpoenas, notices and other processes from this Honorable Office at
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx.
A copy of my authority to file the instant complaint is attached hereto, and made
an integral part hereof, as Annex A.

3.

Pursuant to said authority, I am filing the instant complaint for ESTAFA WITH
ABUSE OF CONFIDENCE defined and penalized under Article 315 paragraph
1(b) of the Revised Penal Code against xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx,
who committed the said crime in the manner specified hereunder:

3.1.

Narration of Fact

3.2.

Narration of Fact

3.3.

Unbeknownst to the complainant, the respondent never submitted the

complainants statement of account. What the respondent submitted was
his own statement of account xxxxxxxxxxxxxxxx.
A copy of the fake statement of account is attached hereto, and made an
integral part hereof, as Annex C.

3.4.

The preparation and submission of the fake statement of account was

without the knowledge, authority and consent of the complainant.

3.5.

Because
of
the
machinations
made
by
the
respondent,
xxxxxxxxxxxxxxxxxxxx
paid
the
amount
of
Pesos:
xxxxxxxxxxxxxxxxxxxx for the fees as evidenced by Check Voucher No.
xxxxxxxxxxxxxxxxxxxx dated xxxxxxxxxxxxxxxxxxxx. The respondent
received the said amount.
A copy of the Check Voucher is attached hereto, and made an integral
part hereof, as Annex D.

3.6.

Despite having received the amount of xxxxxxxxxxxxxxxxxxxx which

rightfully belongs to the complainant, the respondent, with abuse of his
position and with grave abuse of the confidence reposed upon him by the
complainant, only remitted the amount of xxxxxxxxxxxxxxxxxxxx and
misappropriated the amount of xxxxxxxxxxxxxxxxxxxx to the damage
and prejudice of the complainant.

3.7.

Repeated demands were made upon the respondent to return the said
amount, but to no avail, prompting the complainant to send a final
demand letter dated xxxxxxxxxxxxxxxxxxxx to the respondent, which the
respondent received on xxxxxxxxxxxxxxxxxxxx.
A copy of the demand letter is attached hereto, and made an integral part
hereof, as Annex E.

3.8.

Despite his receipt of the demand letter, the respondent failed and
refused to pay any amount to the continuing damage and prejudice of the
complainant.

4.

It is clear from the foregoing that the respondent has committed the crime of
Estafa with Abuse of Confidence.

5.

I am executing this affidavit in support of the complaint of

xxxxxxxxxxxxxxxxxxxx for Estafa with Abuse of Confidence defined and
penalized under Article 315 paragraph 1(b) of the Revised Penal Code, as
amended, against the respondent xxxxxxxxxxxxxxxxxxxx.

FURTHER, AFFIANT SAYETH NAUGHT.

xxxxxxxxxxxxxxxxxxxx
Affiant

SUBSCRIBED and SWORN to before me this ______ day of _________________in

Quezon City, Philippines.

ASSISTANT CITY PROSECUTOR

This is to CERTIFY that I have examined the affiant and that I am satisfied that he
knowingly and voluntarily executed the foregoing Complaint-Affidavit.

ASSISTANT CITY PROSECUTOR