Affidavit COMPLAINT

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Republic of the Philippines)

City of Davao ) SS
x-------------------------------x

AFFIDAVIT – COMPLAINT

I, Antonio C. Benaning, of legal age, Filipino, married and a


resident of Davao City, after having been duly sworn to in accordance
with law, do hereby depose and say, that:

1. I am the Controller of Eden Mountain Resort, Inc., a


domestic corporation operating under its umbrella Eden Nature Park, a
mountain Resort situated at Eden, Bayabas, Toril, Davao City. Attached
herewith as annex “A” is my authority to file the present case.

2. We had one employee in the person of Adresa L. Galviso


who had served the company as Cashier for (4) years. As cashier she
receives from the collector, Jeer D. Gorne the daily collector of the resort.
The total collections she received from Mr. Gorne amounted to Nine
Hundred Sixty One Thousand Seven Hundred Sixty – Four and 61/100
(P961,764.61) covering the Periods from February 11, 2006 to May 25,
2006. Miss Galviso is also tasked to deposit these collections to
Metrobank Toril, Davao City every Friday and Monday of the every week.

Machine copy of Eden Mountain Resort, Inc. Daily Cash and voc –
case Transmittal is herewith attached Annexes: “A – V”, respectively.

3. Of the said total collections received from Mr. Gorne, Miss


Galviso did not deposit the amount of Eight Hundred Sixty Eight
Thousand Seventy – Four Pesos and 71/100 (P868,074.71) in grave
abuse of confidence reposed on her and despite demands to produce the
deposit slips for the said amount or several occasions, Miss Galviso
cannot produce any. We can only conclude she musr have stolen the
said amount with intent to gain for herself and without consent from the
company;

4. On June 1, 2006, Miss Galviso admitted and acknowledged


to have undeposited collections in the aforesaid sum of Eight Hundred
Sixty Eight Thousand Seventy – Four Pesos and 71/100 (P868,074.71)
and despite repeated oral demands, she failed she failed to return the
same, to the damage and prejudice of the company;

Machine copy of Schedule of accountability of Andresa Galviso is


herewith attached annex “W”.

5. In view of the foregoing, the company suffered loss of


income equivalent to aforesaid amount stolen by Miss Galviso; thus, it is
now constrained to engage the services of counsel to file and prosecute
the present case.

6. I am executing this affidavit to apprise to the truth and of


the foregoing allegations for the purpose of initiating QUALIFIED THEFT
cases against the said Andresa L. Galviso who may be served with
processes and warrant of arrest at ____________________.

IN WITNESS WHEREOF, I have hereunto set my hand this ___ day


of June 2006, at Davao City, Philippines.

_______________________________
ANTONIO C BENANING
Affiant
SUBSCRIBED AND SWORN to before me this ___ day of June
2006, at Davao City, Philippines, and hereby certify that I have
personally examined the affiant and I am satisifed that he executed and
understood the foregoing affidavit of his own free will and voluntary act
and deed.

_______________________
REPUBLIC OF THE PHILIPPINES)
CITY OF DAVAO )SS
x--------------------------------------x

AFFIDAVIT OF LOSS
I, SANDRA M. MANLIGOY, of legal age, Filipino, single and a
resident of Blk. 33, Lot 5/7, Suraya Homes, Cabantian, Buhangin,
Davao City, after having been duly sworn to in accordance with law, do
hereby depose and say, that:

1. I am a bona fide holder of the following identification cards:

- PRC-Teacher’s License;
- School Identification Card (University of Mindanao).

2. The foregoing identification cards were stolen along with my


P 1,000.00 cash, when I placed my bag on top of the table at my sister’s
restaurant at 74 Artiaga St., Davao City. The incident happened when I
left the door open while I’m washing my hands in the kitchen on October
11, 2005;

3. I am executing this affidavit to apprise the proper


authorities of the truth and veracity of the foregoing statements for
whatever legal purpose this may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 15th


day of November 2005, at Davao City, Philippines.

__________________________
SANDRA M. MANLIGOY
Affiant

SUBSCRIBED AND SWORN to before me this 15th day of


November 2005, at Davao City, Philippines, affiant exhibited to me her
Community Tax Certificate No. 01975025 issued on January 3, 2005 at
Davao City.

POLICARPIO V. MAYPA. JR.


Notary Public
Until December 31, 2006
PTR No. 2216607; 01-05-05
IBP No. 629317; 01-03-05
Davao City

Doc. No. 14;


Page No. 3;
Book No. XIV;
Series of 2005.
Republic of the Philippines)
City of Davao ) SS
x-------------------------------x

AFFIDAVIT OF LOSS

I, VICKY M. MANLIGOY, of legal age, Filipino, single and a


resident of 103 Borillo’s Apartment, Artiaga St., Davao City,
Philippines, after having been duly sworn in accordance with law
hereby depose and say, that:

1. I am the registered owner of one (1) unit motor vehicle,


particularly described as follows:

Make : Toyota
Type : Sedan;
Motor No. : B3-812167;
Chassis No. : KNADB2222SS207365;
Plate No. : MBX-705;
Year Model : 2003;
Color : White;

2. I am a bona fide holder of Certificate of Registration


No. 81582806 issued by the Land Transportation Office, Davao
Regional Office, Region XI, on August 20, 2003;

3. I inadvertently lost the said Certificate of Registration


and despite earnest efforts to find it, the same can no longer be
found;

4. I am executing this affidavit to apprise the proper


authorities particularly the Land Transportation Office, Davao
Regional Office, Region XI, for the purpose of requesting and
securing a duplicate and/or certified true copy of the same and for
whatever legal purpose this may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this


20 day of November 2004, at Davao City, Philippines.
th

_______________________
VICKY M. MANLIGOY
Affiant

SUBSCRIBED AND SWORN to before me this 20th day of


November 2004, at Davao City, Philippines, affiant exhibited to me
her Community Tax Certificate No. 02165546 issued on January
20, 2004 at Davao City, Philippines.

Doc. No. ______;


Page No. ______;
Book No. ______;
Series of 2004.

REPUBLIC OF THE PHILIPPINES)


CITY OF DAVAO )SS
x--------------------------------------x

AFFIDAVIT OF LOSS

I, POLICARPIO V. MAYPA, JR., of legal age, Filipino, married and a


resident of 45 Ulas, Davao City, after having been duly sworn to in
accordance with law, do hereby depose and say, that:

5. I bought a brown leather strap, stainless case, timex watch


model no. 47802 from Timex, SM Davao on August 8, 2002;

6. When the said timex watch needed repair, I went to Timex, SM


Davao, to have it repaired free of charge as it was still under warranty.
In turn, Timex, SM Davao issued me the duplicate copy of Service
Request Form No. 56145 on June 27, 2003;

7. However, I inadvertently lost the said Service Request Form No.


56145 and despite earnest efforts to find it the same can no longer be
found;

4. I am executing this affidavit to attest to the truth of the


foregoing facts for the purpose of claiming my said timex watch from
Timex, SM Davao and for whatever other legal purpose this may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 26th


day of July 2003 at Davao City, Philippines.

_______________________________
POLICARPIO V. MAYPA, JR.
Affiant

SUBSCRIBED AND SWORN to before me this 26th day of July


2003 at Davao City, Philippines, affiant exhibited to me his Community
Tax Certificate No.16030493 issued on Feb. 19, 2003 at Davao City.
Doc. No. ______;
Page No. ______;
Book No. ______;
Series of 2003.

REPUBLIC OF THE PHILIPPINES)


CITY OF DAVAO )SS
x--------------------------------------x

AFFIDAVIT OF CHANGE OF SURNAME

I, Veryle V. Maypa-Boyles, 37 years of age, Filipino, married to


Augustine Voltaire C. Boyles and a resident of Lemente Village, Mati,
Davao Oriental, after having been duly sworn to in accordance with law,
do hereby depose and say, that:

1. I was born to spouses Policarpio M. Maypa, Sr. and Venus


C.Valdespinosa on September 8, 1965 at V. Luna General Hospital,
Quezon City;

2. At the age of 20 years old, I was married to Augustine


Voltaire C. Boyles on October 8, 1985 at San Nicolas de Tolentino
Cathedral, Mati, Davao Oriental under Marriage License no. 6882598;

3. From then on, I stopped using my maiden name and


started using my married name: “Boyles” in all my transactions and
documents succeeding my marriage;

4. I am executing this affidavit to apprise the proper


authorities and to attest to the truth of the foregoing facts for whatever
legal purpose this may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 30 th


day of May 2003 at Davao City, Philippines.

________________)________________
VERYLE V. MAYPA-BOYLES
Affiant
CTC No. 08478287;
Issued on May 29, 2003
At Mati, Davao Oriental
SUBSCRIBED AND SWORN to before me this 30 th day of May
2003 at Davao City, Philippines, affiant exhibited to me her Community
Tax Certificate No. stated below her name.

Doc. No. ______;


Page No. ______;
Book No. ______;
Series of 2003.

REPUBLIC OF THE PHILIPPINES)


CITY OF DAVAO )SS
x--------------------------------------x

AFFIDAVIT OF LOST PASSBOOK

I, Richard V. Limpot, of legal age, Filipino, single and a resident of


Limatoc, Mati, Davao Oriental, after having been duly sworn to in
accordance with law, do hereby depose and say, that:

1. I am bona fide holder of MT MAS Savings Passbook issued


by Manila Teachers Mutual Aid System;

2. I inadvertently lost or misplaced said passbook ;

3. I exerted earnest efforts to locate it but the same can no


longer be found;

4. I am executing this Affidavit to apprise the proper


authorities particularly the Professional Academic Plans, Inc. of the truth
and veracity of the foregoing facts for the purpose of requesting the
issuance of a new Certificate of Scholarship in lieu of the one lost.

IN WITNESS WHEREOF, I have hereunto set my hand this 16th


day of July, 2002 at Davao City, Philippines.
__________________________________
MA. ARLENE T. MERCADO
Affiant
CTC No. 14336794
Issued on Feb. 22, 2002
At Davao City

SUBSCRIBED AND SWORN to before me this 16th day of July


2002 at Davao City, Philippines, affiant exhibited to me her Community
Tax Certificate No. indicated below her name.

POLICARPIO V.
MAYPA. JR.
Notary Public
Until December 31,
2002
PTR No.6273080; 01-
02-02
IBP No.539704; 12-11-
01
Davao City

Doc. No. ______;


Page No. ______;
Book No. ______;
Series of 2002.

REPUBLIC OF THE PHILIPPINES)


CITY OF DAVAO )SS
x--------------------------------------x

AFFIDAVIT OF LOSS

I, Marla E. Mercado, of legal age, Filipino, married and a resident


of 161 Mariveles St., Central Park Subd., Bangkal, Davao City, after
having been duly sworn to in accordance with law, do hereby depose and
say, that:

4. I am a bona fide policy holder of a Memorial Plan with PNA #


302172-6 & 302173-4 issued by the Pacific Plans, Inc.;

2. I lost the hard copy of the said policy a few years back when
my family and I transferred our residence from #1 Vienna St., Merville
Park Subd., Parañaque to #161 Mariveles St., Central Park Subd.,
Bangkal, Davao City;

3. I exerted earnest efforts to locate the said policy but the


same can no longer be found;

4. I am executing this affidavit to apprise the proper


authorities particularly Pacific Plans, Inc., Planholders Accounts &
Conservation Department of the truth and veracity of the foregoing
statements for whatever purpose this may serve.

AFFIANT FURTHER SAYETH NONE.

IN WITNESS WHEREOF, I have hereunto set my hand this 23rd


day of May, 2002 at Davao City, Philippines.

__________________________
MARLA E. MERCADO
Affiant
CTC No.2627657
Issued on Jan. 8, 2002
At Davao City

SUBSCRIBED AND SWORN to before me this 23rd day of May


2002 at Davao City, Philippines, affiant exhibited to me her Community
Tax Certificate No. as indicated below her name.

Doc. No. ______;


Page No. ______;
Book No. ______;
Series of 2002.

REPUBLIC OF THE PHILIPPINES)


CITY OF DAVAO )SS
x--------------------------------------x

AFFIDAVIT OF LOSS

I, Anthony R. Hilomen, of legal age, Filipino, married and a


resident of 1122 Purok dela Cruz, Mankilam, Tagum City, after having
been duly sworn to in accordance with law, hereby depose and say, that:

5. I am the branch marketing supervisor of Mindanao Water


Bottling Corporation (MWBC for brevity) based in Tagum City;

2. On separate occasions, MWBC delivered APO Natural


Spring Water to the Governor’s House in Tagum City as evidenced by the
issued Charge Invoices hereto attached as follows:

Charge Invoices Nos. Date Issued: Charged to:

26887 4-10-2001 Governor’s


House
27364 4-18-2001 Governor’s
House
31807 6-27-2001 Governor’s
House
31949 7-04-2001 Governor’s
House
32543 7-11-2001 Governor’s
House

3. Sometime on May 2001, the employees in-charged of


keeping the original copies of the foregoing Charge Invoices inadvertently
lost them and despite earnest efforts to find them, the same can no
longer be found;

4. I am executing this affidavit to apprise the proper


authorities particularly Governor’s House of the truth and veracity of the
foregoing statements for whatever legal purpose this may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 9th day


of May 2002 at Davao City, Philippines.

____________________________
ANTHONY R. HILOMEN
Affiant
CTC No. 04958301; 1-28-2002
Davao City

SUBSCRIBED AND SWORN to before me this 9th day of May 2002


at Davao City, Philippines, affiant exhibited to me his Community Tax
Certificate Number as indicated below his name.

Doc. No. ______;


Page No. ______;
Book No. ______;
Series of 2002.

REPUBLIC OF THE PHILIPPINES)


CITY OF DAVAO )SS
x--------------------------------------x

AFFIDAVIT OF LOSS

I, Anthony R. Hilomen, of legal age, Filipino, married and a


resident of 1122 Purok dela Cruz, Mankilam, Tagum City, after having
been duly sworn to in accordance with law, do hereby depose and say,
that:

6. I am the branch marketing supervisor of Mindanao Water


Bottling Corporation (MWBC for brevity) based in Tagum City;

2. On separate occasions, MWBC delivered APO Natural


Spring Water to Hijo Plantation, Inc. (HPI) as evidenced by the following
Charge Invoices hereto attached to form integral part hereof:

Charge Invoices Nos. Date Issued: Charged to:

21872 1-08-2001 Hijo Plantation, Inc.


24923 3-06-2001 Hijo Plantation, Inc.
28496 5-12-2001 Hijo Plantation, Inc.
28497 5-12-2001 Hijo Plantation, Inc.
28916 5-15-2001 Hijo Plantation, Inc.
28917 5-15-2001 Hijo Plantation, Inc.
28921 5-15-2001 Hijo Plantation, Inc.

3. Sometime on May 2001, the employee in-charged of keeping


the original copies of the foregoing Charge Invoices inadvertently lost
them and despite earnest efforts to find them, the same can no longer be
found;

4. I am executing this affidavit to apprise the proper


authorities particularly Hijo Plantation, Inc. of the truth and veracity of
the foregoing statements for whatever legal purpose this may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 6th day


of May, 2002 at Davao City, Philippines.

____________________________
ANTHONY R. HILOMEN
Affiant
CTC No. 04958301; 1-28-2002;
Davao City

SUBSCRIBED AND SWORN to before me this 6th day of May 2002


at Davao City, Philippines, affiant exhibited to me his Community Tax
Certificate Number as indicated below his name.

Doc. No. ______;


Page No. ______;
Book No. ______;
Series of 2002.
REPUBLIC OF THE PHILIPPINES)
CITY OF DAVAO )SS
x--------------------------------------x

AFFIDAVIT OF LOSS

I, Noel A. Taganahan, of legal age, Filipino, married and a resident


of Davao City, after having been duly sworn to in accordance with law,
do hereby depose and say, that:

7. I am the marketing in-charge of Powertech Specialists, Inc.


(Powertech for brevity) a corporation duly organized and existing under
Philippine laws with principal office address at Matinee Town Square,
MacArthur Highway, Matina, Davao City;

2. That sometime on September 2001, the said Purchase


Order No. 22755 invoices issued by the Water District were lost and
despite earnest efforts to find them, the same can o longer be found:

4. I am executing this affidavit to apprise the proper


authorities particularly DAVAO WATER DISCTRICT of the truth and
veracity of the foregoing statements for whatever legal purpose this may
serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 4 th day


of December, 2001 at Davao City, Philippines.

____________________________
NOEL A. TAGANAHAN
Affiant
CTC No. 18941034; 1-05-2001;
Davao City
SUBSCRIBED AND SWORN to before me this 4th day of December,
2001 at Davao City, Philippines, affiant exhibited to me his Community
Tax Certificate No. indicated below his name.

Doc. No. ______;


Page No. ______;
Book No. ______;
Series of 2001.

REPUBLIC OF THE PHILIPPINES)


CITY OF DAVAO )SS
x--------------------------------------x

AFFIDAVIT OF LOSS

I, Virgo John R. Ventura, of legal age, Filipino, married and a


resident of Blk. 17 Lot 12 Pag-ibig Country Homes, Catalunan Pequeño,
Davao City, after having been duly sworn to in accordance with law, do
hereby depose and say, that:

8. I am the marketing in-charge of Mindanao Water Bottling


Corporation (MWBC for brevity) a corporation duly organized and existing
under Philippine laws with principal office address at JFM Corporate
Center, 848 Atis St., Juan Subd., Matina, Davao City;

2. On separate occasions, the said corporation delivered APO


Natural Spring Water to Mr. Antonio Floirendo and Mr. Anton Lagdameo
charged for the account of Tagum Development Corporation (TADECO),
as evidenced by the following charged invoices, herewith attached to form
integral part hereof:

Charge Invoices Nos. Date Issued: Charged to:

32296 7-09-2001 Antonio Floirendo


34010 7-16-2001 Antonio Floirendo
34153 7-23-2001 Antonio Floirendo
34191 7-30-2001 Antonio Floirendo
34647 8-06-2001 Antonio Floirendo
35306 8-13-2001 Antonio Floirendo
35714 8-20-2001 Antonio Floirendo
33036 7-13-2001 Anton Lagdameo

34495 7-27-2001 Anton Lagdameo


35175 8-10-2001 Anton Lagdameo
37071 9-07-2001 Anton Lagdameo
37342 10-5-2001 Anton Lagdameo
37394 9-20-2001 Anton Lagdameo

3. Sometime on October, 2001, the original copy of the said


charge
invoices were lost by the employees of the MWBC who issued them and
despite earnest efforts to find them, the same can o longer be found:

4. I am executing this affidavit to apprise the proper


authorities particularly TADECO of the truth and veracity of the
foregoing statements for whatever legal purpose this may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 7 th day


of November, 2001 at Davao City, Philippines.

____________________________
VIRGO JOHN R. VENTURA
Affiant
CTC No. 12887131; 4-06-2001;
Davao City

SUBSCRIBED AND SWORN to before me this 7 th day of November,


2001 at Davao City, Philippines, affiant exhibited to me his Community
Tax Certificate No. indicated below his name.

Doc. No. ______;


Page No. ______;
Book No. ______;
Series of 2001.

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