REPUBLIC OF THE PHILIPPINES )

CALOOCAN CITY
)S.S.

COMPLAINT-AFFIDAVIT
I, ROMULO B. KIPTE, of legal age, widower, Filipino and a resident of Purok4, Sto. Cristo, Tabaco City, Albay, Bicol, after having been duly sworn in accordance
with law, hereby depose and state that:
1. I am the surviving spouse of LEONILA B. KIPTE who died on November 13,
2004 in Tabaco City, Albay, Bicol.
2. She was a former teacher at Tabaco South Central Elementary School, Albay
Bicol from year 1985 to 2004.
3. In year 2002, we decided to engage in money lending using the money I
earned from my livestock business. Majority of our borrowers were her coteachers at the Tabaco South Central Elementary School. We extended loans
ranging from One thousand pesos (P1,000.00) to Fifteen thousand pesos (P
15,000.00).
4. My deceased spouse and I extended the following loans to the following
public school teachers:
a.
b.
c.
d.
e.
f.
g.
h.
i.
j.
k.
l.
m.
n.
o.
p.
q.
r.
s.
t.

Caridad Romabon
Ma. Girlie P. Serrano
Lydia B. Bragais
Psyche Bocalig
Divina Capuz
Elsa Borleo
Aurora Ceruelos
Josefina Borbe
Daphne Burac
Jelly Puensalida
Herminia Berces
Julma B. Torre
Minda Box
Raquel C. Ardales
Evelina B. Berces
Leticia B. Brobio
Salvacion Buella
Linda Adtoon
Richelda Duran
Arlene Celestial
Total:

P5,000.00
P15,000.00
P5,000.00
P10,000.00
P5,000.00
P10,000.00
P3,000.00
P3,000.00
P5,000.00
P5,000.00
P10,000.00
P5,000.00
P2,000.00
P10,000.00
P10,000.00
P2,000.00
P5,000.00
P1,000.00
P2,000.00
P2,000.00

retired

retired
retired
retired
retired
retired
retired

P115,000.00

5. These loans were not yet paid when my wife LEONILA B. KIPTE died on
November 13, 2004. Photocopies of the dated and signed acknowledgment
receipt executed for each loan is attached hereto, referred to as ANNEX A.
6. Two years later, I orally demanded the payment of their obligation with my
lawyer ATTY. RENATO DIOSDADO C. KALLOS, JR. in a meeting that took place
at my lawyers residence.
7. Unfortunately, my demands fell on deaf ears and all the respondent-teachers
claimed that they already paid the amount they respectively borrowed.

8. I scheduled another meeting with the said teachers one month after the first
meeting but they did not show up. They ignored my persistent demands.

9. I am deeply aggrieved by their indifference and unresponsiveness to my

pleas. As teachers, they are the first persons who are expected to lead by
example, observe honesty and good faith in all their dealings and practice
empathy. However, their conduct clearly shows their lack of respect not only
to me but also to my deceased spouse who was kind enough to trust them
by lending substantial amount of money. It is clear that respondents took
advantage of the death of my wife LEONILA B. KIPTE to escape their
obligations.
10.
The above acts clearly constitute misconduct and conduct unbecoming
of a public school teacher.
11.
That I am executing this sworn statement in truth and for the purpose
of charging respondents CARIDAD ROMABON, MA. GIRLIE P. SERRANO,
LYDIA B. BRAGAIS, PSYCHE BOCALIG, DIVINA CAPUZ, ELSA BORLEO,
AURORA CERUELOS, JOSEFINA BORBE, DAPHNE BURAC, JELLY
PUENSALIDA, HERMINIA BERCES, JULMA B. TORRE, MINDA BOX,
RAQUEL C. ARDALES, EVELINA B. BERCES, LETICIA B. BROBIO,
SALVACION BUELLA, LINDA ADTOON, RICHELDA DURAN, and ARLENE
CELESTIAL with MISCONDUCT and CONDUCT UNBECOMING OF A
PUBLIC SCHOOL TEACHER before the Office of the Ombudsman.
IN WITNESS WHEREOF, I have hereunto set my hand this 12th day of
February, 2015 in Caloocan City, Philippines.

ROMULO B. KIPTE
Affiant
With Senior Citizens I.D. No. 10102,
Tabaco City, Albay, Bicol
SUBCRIBED AND SWORN TO before me this 12th day of February, 2015 in
Caloocan City, Philippines, affiant exhibiting to me his valid proof of identification.

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2015.

REPUBLIC OF THE PHILIPPINES )

CALOOCAN CITY

)S.S.

CERTIFICATION OF NON-FORUM SHOPPING

I, ROMULO B. KIPTE, of legal age, widower, Filipino and a resident of Purok4, Sto. Cristo, Tabaco City, Albay, Bicol, after having been duly sworn in accordance
with law, hereby depose and state that:
1. I have not earlier commenced a similar action against the respondents
for the same cause with any other court, tribunal, or quasi-judicial
agency;
2. No such action or proceeding is pending with any other court, tribunal,
or quasi-judicial agency;
3. If I should learn that a similar action or proceeding has been filed or is
pending before any other court, tribunal, or quasi-judicial agency, I
hereby undertake to notify this Honorable Office within five (5) days
from such notice.

ROMULO B. KIPTE
With Senior Citizens I.D. No. 10102,
Tabaco City, Albay, Bicol

SUBCRIBED AND SWORN TO before me this 12th day of February, 2015 in

Caloocan City, Philippines, affiant exhibiting to me his valid proof of identification.

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2015.