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Affidavit Complaint PDF

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Republic of the Philippines

Department of Justice
NATIONAL PROSECUTION SERVICE
OFFICE OF THE PROVINCIAL PROSECUTOR
Province of Negros Occidental
Bacolod City

REPUBLIC OF THE PHILIPPINES)


CITY OF MUNTINLUPA ) S.S.

AFFIDAVIT-COMPLAINT

I, IMELDA C. DIAZ, of legal age, Filipino, married with business


address at 25 Madrigal Avenue, Alabang, Muntinlupa City depose and state that:

1. I am the Manager and duly authorized representative of Justeas


Milk Tea Corporation, or “Justeas” for brevity, a corporation duly organized
and existing under the Philippine laws, with principal address at 25
Madrigal Avenue, Alabang, Muntinlupa City;

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


accuse PACITA L. CAJAYON, cashier of Justeas Tea Shop, Lacson
Branch, of legal age with residential address at 83 Ocampo St. Jude
Thadeus Bacolod City, where she can be served with legal processes of
the crime of ESTAFA BY MEANS OF ABUSE OF CONFIDENCE under the
Revised Penal Code;

3. The submission and falsification of the sales and sales reports from
August 2015 to FEBRUARY 2016 was committed in Muntinlupa City
together with the misappropriation of the cash sales of Justeas products
was committed by the respondent in the following manner to wit:

3.1 I am the Branch Manager of Justeas Milk Tea Corporation since 2018;

3.2 PACITA L. CAJAYON was employed by Justeas in June 2018 as


cashier at the Justeas Tea Shop Alabang branch;

3.3 Respondent was assigned with cashier work at said branch together
with the remittance of the sales and submission of sales reports at the
end of each week;
3.4 On DECEMBER 2018, I received verbal reports from MARIO G.
PINEDA, Branch Accountant about the inconsistencies in the sales
report despite the good sales performance of the Alabang branch;

3.5 Acting on the Information that I received from MARIO G. PINEDA, an


audit team spearheaded by MARIO G. PINEDA was formed to conduct
a thorough examination of the sales and sales report made of
respondent as branch cashier from June 2014 to February 2016;

3.6 Based on the Audit Report submitted by MARIO G. PINEDA, the


following were the findings to wit:

A) “Upon further checking by the undersigned (MARIO G. PINEDA)


of PACITA L. CAJAYON’S sales and sale reports, there was a significant
difference between the sales on the sales reports and the actual sales made as
reported by the other employees of the Justeas Tea Shop. Also noted on F.
Magallanes trip tickets were the absence of products sold, which should have
been stated in the sales reports.

B) That upon checking backwards of the Alabang branch sales


reports, A TOTAL OF 5,042 cups of Milk Teas were sold, AMOUNTING TO PHP
478,990 FROM AUGUST 2015 TO FEBRUARY 2009, AS OPPOSED TO WHAT
WAS WRITTEN IN THE SALES REPORTS WHICH ONLY REPORTED A SALE
OF 3,100 CUPS WHICH AMOUNTED TO PHP 294,500. A total of P184,490 was
in discrepancy.

On 4 March 2018, I requested respondent to explain in writing the


discrepancies in the actual sales and the sales reports submitted. Respondent
readily admitted to me her wrongdoing.

Sensing that the management would conduct further investigations on the


matter, respondent did not report for work for three day after the confrontation. I
sent her a notice to report for work together with a demand letter sent by the
company lawyer. Respondent stopped reporting to work after the letters were
sent to her. Despite the corporation’s efforts in trying to locate respondent, she
could not be found anymore.

Even when the notice to report to work and the demand letter sent to the
last known address of respondent, she failed and continued to refuse to report for
work to the damage and prejudice of Justeas.

Respondent’s acts of falsifying the sales reports to conceal the actual


sales made by Justeas Tea Shop Alabang branch by respondent and
misappropriating the undeclared cash sales in the amount of ONE HUNDRED
AND EIGHTY FOUR THOUSAND FOUR HUNDRED NINETY PESOS (P184,
490.00) submitted to

Justeas Milk Tea Corporation in its principal office in Muntinlupa City and
by refusing and failing to pay the same has deprived Justeas of the use and
enjoyment of said amount to its damage and prejudice.

AFFIANTS FURTHER SAY NONE.

IMELDA C. DIAZ
Affiant

SUBSCRIBED AND SWORN to before me this 21 day of March 2018 at


Valenzuela City.

ATTY. CARLO MARTIN FERNANDEZ


Notary Public-Cities of Bacolod
Talisay Mun. Murcia & Don Salvador
Neg. Occ. NP No. 0092-19, Until Dec.31, 2019
PTR. No. 1896636 Roll No. 87022

CERTIFICATION

I HEREBY CERTIFY that I have personally examined the


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

ATTY. CARLO MARTIN FERNANDEZ


Notary Public-Cities of Bacolod
Talisay Mun. Murcia & Don Salvador
Neg. Occ. NP No. 0092-19, Until Dec.31, 2019
PTR. No. 1896636 Roll No. 87022

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