DEPARTMENT OF JUSTICE OFFICE OF THE CITY PROSECUTOR Taguig City, Metro Manila
KRISTINE JOY MEDRANO,
Complainant,
- Versus - I.S. No. ________________
For: Estafa and/or Other Deceits
ALEX RODRIGUEZ, Respondent. X * * * * * * * * * X
COMPLAINT – AFFIDAVIT
I, KRISTINE J. MEDRANO, of legal age, Filipino Citizen, and with
address at _________________________, after having been duly sworn to in accordance with law, do hereby depose and state:
1. That I am the Private Complainant in the afore-entitled
Case;
2. That Respondent, ALEX RODRIGUEZ, is of legal age,
Filipino Citizen and with address at ____________________________;
3. That I am an employee of FAIR ALL MARKETING, a
__________________________________ duly organized and registered under and by virtue of the laws of the Republic of the Philippines with office address at _________________________________________ end engaged in the business of selling and supplying Firefighting Equipments;
4. That as employee of Fair All Marketing, I am charged
among others, with the duty of participating in the bidding, processing bidding documents relative to the procurement of firefighting equipments and transacting business for the procurements and orders of firefighting equipments and deliveries of said equipments;
5. That sometime on ______________________, Ms. Clair B.
Ernesto, my co-employee, was directed by our Operations Manager, Helen Yuso, to attend and observe bidding processes and/or procedures being conducted at the Philippine Army at ___________________________________________________________;
6. That after having attended and observed said bidding
processes and / or procedures, Ms. Clair B. Ernesto intimated to me that certain Alex Rodriguez, herein respondent, introduced himself to Ms. Clair Ernesto as a representative of RICHMOND, a _________________________ and asked Clair if she would like to buy bidding documents to which Clair replied she is does not want to. That Alex Rodriguez, herein respondent, told and represented to Clair that he has the necessary connection, influence and the “in and outs” of bidding at the Philippine Army.
7. Respondent also introduced to Clair, one Sharon
Villanueva who claimed to be a member of BAC of the the Philippine Army who asked Clair that if she asking for bidding documents, she should buy the same;
8. That thereafter, Ms. Clair Ernesto told our Operations
Manager, Helen Yuso, all that she intimated to me, particularly that statement and representation of respondent Alex Rodriguez that he the necessary connection, influence and the “in and outs” of bidding at the Philippine Army;
9. That upon the instructions of Madam Helen Yuso, Ms. Clair
Ernesto talked with respondent Alex Rodriguez to undertake the bidding and bidding process of government procurements and orders and from then on, respondent apprises and provides Ms. Clair Ernesto of informations relative to Government biddings and procurements to Ms. Clair