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Department of Justice
NATIONAL PROSECUTION SERVICE
CITY PROSECUTION SERVICE OF MANILA
City of Manila
BEAREAN LOGISTICS SERVICES
Complainant;
-versus-
I.S.________________
For: Qualified Theft
COMPLAINT- AFFIDAVIT
Complainant, BEAREAN LOGISTICS SERVICES, an entity
duly established and registered in accordance with the laws of the
Republic of the Philippines and maintains an official place of
business at Room 511, Madrigal Building, Escolta Street, Binondo,
Manila City, through the undersigned counsel, respectfully avers
that;
1. The complainantis engaged in the business of providing
logistics, trucking and other ancillary services to the
public and is duly registered under pertinent laws.
Attached and made an integral part of this complaintaffidavit is a copy of registration with the Department of
Trade and Industry marked as Annex A.
2. In the regular course of business of the complainant, the
latter hired the services of Mr. Dandin Trinidad Secretario,
referred hereto as Respondent, as its Liaison, Utility and
Billing Officer whose primary function involves the
following:submission of documents with billing details to
clients and collection of the same, to make necessary
withdrawals and deposits as instructed, payment of
company bills and the processing of import related
transactions. Attached and made an integral part of this
complaint-affidavit is a copy of the Employment Contract
of the respondent marked as Annex B.
3. As mentioned above, part of the functions of the
respondent is to withdraw from the complainants bank
account upon order of his superiors. In the performance of
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