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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 ofJusteas Tea Shop, Alabang Branch, of legal
age with residential address at 83 Ocampo St. Las PinasCity,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 2016was committed in MuntinlupaCity together with
the misappropriation of the cash sales of Justeas products was committed by the
respondentin the following manner to wit:

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


2010;

3.2 PACITA L. CAJAYONwas employed by Justeasin June 2014 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 2015, 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.
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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.

4. On 4 March 2016, 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.

5. 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.

6. 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.

7. 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 deprivedJusteas 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 ______ day of December 2009


at ValenzuelaCity.

___________________________
AssistantCity Prosecutor

CERTIFICATION

I HEREBY CERTIFY that I have personally examined the affiant-complainant


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

___________________________
AssistantCityProsecutor
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