REPUBLIC OF THE PHILIPPINES)

CITY OF CEBU ) S.S.

AFFIDAVIT-COMPLAINT

I, PEDRO PINDOKO, of legal age, Filipino, married with business

address at Panganiban St., Pahina Central, Cebu City depose and state:

1. That I am the Owner and representative of Lugod Maker’s Company

(LMC) for brevity, a corporation duly organized and existing under the Philippine
laws, with principal address at Cebu City.

2. That after having duly sworn to in accordance with law, I do hereby

accuse JUAN DELA CRUZ, logod maker, of legal age with residential address at Cebu
City, where he can be served with legal processes of the complex crime of ESTAFA
WITH ABUSE OF CONFIDENCE under the Revised Penal Code.

3. That the submission and falsification of the purchase receipt on August

1, 2007 was committed in Cebu City and the misappropriation of the cash was
committed by the respondent in the following manner to wit:

3.1 That I am the Owner of the business LUGOD MAKER’S COMPANY.

3.2 That JUAN DELA CRUZ was employed by LMC since 2003 as logod
maker.

3.3 That respondent was instructed to buy a material for the making
of the product of the company in Cebu City on August 1, 2007.
That it is incumbent upon him to remit the receipt and the excess
of the money from the purchase price to Plaintiff Company in its
office in Cebu City.

3.4 Upon receiving the receipt of the purchase, I recognized that

there was an indication that the receipt was tampered.

4. That on the same date, I requested respondent to explain the

discrepancy in the receipt. Respondent readily admitted to me his wrongdoing and
in fact offered that he will pay for the money that he had misappropriated in
installment.

5. Truth to tell, respondent did not return the tampered receipt and
insisted that he allegedly returned the said receipt were in fact the receipt is still in
his possession, which forced the company owner to ask for the receipt from the
hardware where the materials had been purchased.

6. That he was ordered to return to work by sending him a “return to

work order” which he signed therein indicating that he is willing to work but upon
sensing that during his course of work he might be subject to an investigation he
did not show up.

7. Obviously, respondent fearing the filing of criminal case chose not to

report for work without any leave of absence. FLIGHT IS INDICATIVE OF
GUILT.
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8. In spite of the receipt of said notices which was sent in the given
address of the respondent based on their 201 files, respondent failed and refuse to
report for work to the damage and prejudice of the company.

9. That respondent’s acts of tampering the receipt to conceal the actual

amount paid for the purchase material declaring excessive price in the amount of
THREE THOUSAND PESOS (PHP 3000.00) submitted to Lugod Makers
Company in its office in Cebu City and by refusing and failing to pay the same has
not only deprived the company of the use and enjoyment of said amount to its
damage and prejudice LMC.

AFFIANTS FURTHER SAY NONE.

PEDRO PINDOKO
Affiant

SUBSCRIBED AND SWORN to before me this ______ day of January 2008 at

Cebu City, Philippines.

I FURTHER CERTIFY that I have personally examined the affiant-complainant

and that I am satisfied that he voluntarily executed and understood his Complaint-
Affidavit.

Atty. Harvy S. Halasan

Counsel for the Complainant
Notary Public
PTR No. 54672390
IBP No. 689075
Rule No. 56783
MCLE No. 3242