Republic of the Philippines)

______________________) S.S
x----------------------------------------x

AFFIDAVIT - COMPLAINT
I, ________________, of legal age, Filipino, married and with office address
at ________________________________________, after having duly sworn to in
accordance with law hereby depose and state that:

1. I am the ____________________ and duly authorized representative of

________________________________, a corporation duly organized and
existing under the Philippine laws with principal office address at
_______________________________________;
Attached and marked as EXHIBIT “A” is the
Secretary’s Certificate appointing “ ”as the
authorized representative of “ ” to file a criminal
case for and on behalf of “__________”.

2. This affidavit-complaint is for the purpose of filing a criminal case for

estafa punishable under Article 315 of the Revised Penal Code or for any
other such crime/s as may be determined by the Office of the City
Prosecutor against Mr. _________________________________, of legal
age, Filipino and a resident of
_________________________________________________;

3. As an ______________________________, I was assigned/authorized to

buy Firearms of the Company, __________________________, to be used
by our ___________________________ in their respective detachments;

4. We looked for some prospect suppliers of firearms and there were four (4)
suppliers which we considered. These are ____________, _________,
_______________ and ____________________;

5. The last mentioned supplier, _________________________, was

recommended to us by an employee from _________________ who also
gave us the contact number of the said store. It is owned by
_______________________.

6. On ___________________, we contacted the four (4) suppliers and made

some inquiry and asked for a quotation for 27 units of 9mm (hand gun)
and 5 units of 12GA (shot guns).

7. On _____________________, _________________________ sent its

quotations.
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 Attached and marked as EXHIBIT “B” is a copy of
the quotation sent by “________________________”.

8. I made a supplier canvass sheet based on the quotations sent by the

participating suppliers and among the three (3) suppliers who actually
sent their quotations, _______________________ has the lowest price to
offer.
Attached and marked as EXHIBIT “C” is a copy of
the said Canvass Sheet.

9. I presented the quotations and the Supplier Canvass sheet to our Chief
Admin & Technical Officer, __________________, and we agreed to buy
the needed firearms from ___________________, since it offers the
lowest price;

10. I prepared the Purchase Order (P.O.) for the approval of our President,
________________________, III and upon his approval, I immediately
contacted the owner of the store, _________________, and sent him the
approved P.O.;

11. I then requested from our Accounting Department the payment of the 32
Firearms amounting to _______________________________
(P_________) and the payment for the processing fee of firearms license
and firearms bond in the amount of ___________________________
(P_____________).

12. As he represented himself as one of the legitimate suppliers of firearms in

Camp Crame and since he is also known to some personnel from FEO
Office, I trusted ____________________ and I agreed that we will pay him
the whole amount on ____________________, while the delivery of the
firearms shall be made two to three weeks after payment.
____________________ even suggested that the payment be done at
Camp Crame FEO Office.

13. On _______________, I was accompanied by my officemates

______________________ , __________________ , and
____________________ in going to the FEO Office in Camp Crame,
Quezon City to give the payments to ____________________;

14. After deducting the corresponding taxes (Expanded Withholding Tax), we

paid _________________ the amount of _____________________
(P___________) for the firearms (less EWT) and ____________________
(P_________) for the processing fee of firearms license and firearms
bond.

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15. The payment of the Firearms as well as the payment of processing fee of
firearms license were made through Checks. The payment of Firearms was
divided into two checks, hence, each check amounted to
_______________________________ (P________________) for a total
______________________________________ (P__________), less EWT.
_________________ then issued receipts for the payment of firearms and
payment of the processing fee.
Attached and marked as EXHIBITS “D” and “E” are
copies of the Official Receipts for the payment of
firearms and the processing of licenses and bonds,
respectively.

16. The said checks were immediately encashed by _________________ as he

himself confirmed that to me by our Accounting Department.
Attached and marked as EXHIBITS “F” to “F-1” is a
copy of the transaction history / bank statement
showing that the checks issued to “_________” were
encashed and/or debited from the account of
“________”.

17. Mr.___________ assured that he will deliver the firearms to our Office
two to three weeks upon payment as agreed.

18. On 19 September 2018, I called him to follow up on the delivery of the

firearms but I did not receive any reply from him. On the following day or
on 20 September 2018, I again texted Mr.____________ to follow up and
he said that they are still waiting for the release of the ballistics test;

19. Another follow up was made on 21 September 2018 but for the same
reason, he cannot give yet the serial numbers as they are still waiting for
the result of the ballistics test. He even said that if ballistic test will not be
released on the said date, he will replace the Norinco with rock island
without any cost;

20. On 25 September 2018, I again made a follow up and Mr. Cisneros assured
that he could already get the ballistic test.
Attached and marked as EXHIBITS “G” to “G-4”
are copies of the screenshot of text messages between
me and Mr. _____________.

21. On 02 October 2018, we set a meeting with Mr. _______________ at our

Office in Pasig City where he apologized for the delay in the delivery of our
firearms and promised that he will deliver them the following week;

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 22. On 08 October 2018, I called Mr. ____________ to follow up on the status
of the serial numbers and the delivery of the firearms but he is no longer
answering my calls;

23. On 30 October 2018, the first demand letter was sent to Mr.
___________________ through LBC and was received by Mr.
___________________ himself on 31 October 2018 as evidenced by LBC
Tracking Receipt.
Attached and marked as EXHIBIT “H”, “I” and “J” are
copies of the Demand Letter, LBC receipt and LBC Tracking
Receipt.

24. Despite receipt of the Demand Letter, Mr. ________________ never

bothered to contact me and give me an update on the status of the
delivery of the firearms that we purchased and fully paid. Worse, I can no
longer contact him;

25. A second demand letter was then sent on 21 November 2018.

Attached and marked as EXHIBITS “K”, “L” and “M” are
copies of the Second Demand Letter, LBC Receipt and LBC
Tracking Receipt.

26. Said second demand letter was again ignored by Mr.

___________________, as such we decided to send him our 3 rd and final
demand letter.
Attached and marked as EXHIBITS “N”, “O” and “P” are
copies of the Third Demand Letter, LBC Receipt and LBC
Tracking Receipt.

27. Undeniably, Mr. Cisneros through the employment of fraud and deceit
gained the aggregate amount of __________________________
(P______________), to our company’s prejudice.

28. That I am executing this affidavit-complaint freely and voluntarily as I

attest to the truthfulness and veracity of the above-mentioned facts;

IN WITNESS WHEREOF, I have hereunto set my hand this ___ day of February
2019 at ___________________.

__________________
Affiant

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 SUBSCRIBED AND SWORN to before me this _____ day of February 2019 at
___________________.

ADMINISTERING OFFICER

CERTIFICATION

This is to certify that I have personally examined the Affiant and I am

convinced that this AFFIDAVIT-COMPLAINT is freely and voluntarily executed by
him and that the same is true and correct to the best of his knowledge.

ADMINISTERING OFFICER