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 Makers
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
COMPANY.

That I am the Owner of the business LUGOD MAKERS

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.
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 respondents 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 affiantcomplainant 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