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REPUBLIC OF THE PHILIPPINES

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

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