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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 of Justeas Tea Shop,
Alabang Branch, of legal age with residential address at 83 Ocampo
St. Las Pinas City, 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 2016 was committed in
Muntinlupa City together with the misappropriation of the cash sales
of Justeas products was committed by the respondent in the
following manner to wit:
3.1

I am the Branch Manager of Justeas Milk Tea


Corporation since 2010;

3.2

PACITA L. CAJAYON was employed by Justeas in 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.
CAJAYONS 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.
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 corporations 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.

Respondents 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 deprived Justeas 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 Valenzuela City.

___________________________
Assistant City Prosecutor
CERTIFICATION
I HEREBY CERTIFY that I have personally examined the affiantcomplainant and that I am satisfied that he voluntarily executed and
understood his Complaint-Affidavit.

___________________________
Assistant City Prosecutor