REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
CITY PROSECUTOR’S OFFICE
CEBU CITY

ABC CORPORATION
Complainant CRIMINAL CASE NO. 14344
FOR:
-versus-

MR. JERRY LATORRE

Respondent
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COMPLAINT

Complainant, through the undersigned counsel, through this Honorable

Office respectfully alleges;
1. That Complainant-Corporation is a duly existing for and by virtue of
the laws of the Republic of the Philippines with principal office at
Sambag 1, Urgello, Cebu City where it may be served with
summons;
2. That sometime on January 2001, Complainant-Corporation engaged
in the sale of motorcycles, decided to rent a lot in Toledo City for
the purpose of putting up a motorcycle store owned by Lourdes
Limbaga who was also a board of director of ABC Corporation;
3. That the lot was occupied by the accused because he is the
caretaker of Lourdes Limbaga;
4. Complainant-Corporation decided to take the accused as the
manager of their motorcycle store with the salary of P1, 500.00 a
month plus 30% commission on any motorcycle he sold;
5. When the accused agreed to the terms and conditions of the
Complainant-Corporation, complainant demolished a portion of the
house of the accused and placed a small one(1)- storey building
served as the store;
6. After three years of operations, the store was not profiting and the
accused cannot account for the sales amounting to P100,000.00;
7. That no compromise agreement was reached between the parties.

WHEREFORE, it is respectfully prays for judgment in his favor

through a decision XXXXXX
 VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

I, ABC Corporation, a domestic corporation duly organized and existing

under and by virtue of the laws of the Philippines, after having been duly
sworn in accordance with law, depose and state that:

1. I am the complainant in the above-stated case;

2. I caused the preparation of the foregoing complaint;

3. I have read the contents thereof and the facts stated therein are true and
correct of my personal knowledge and/or on the basis of copies of
documents and records in my possession;

4. I have not commenced any other action or proceeding involving the same
issues in the Supreme Court, the Court of Appeals, or any other tribunal or
agency;

5. To the best of my knowledge and belief, no such action or proceeding is

pending in the Supreme Court, the Court of Appeals, or any other tribunal or
agency;

6. If I should thereafter learn that a similar action or proceeding has been

filed or is pending before the Supreme Court, the Court of Appeals, or any
other tribunal or agency, I undertake to report that fact within five (5) days
therefrom to this Honorable Court.

___________________________
AFFIANT

SUBSCRIBED AND SWORN to before me this 20th day of

September, 2016 in City of Cebu, the affiant who exhibiting to me
his/her Community Tax Certificate NO.: 12-0502488881-4 issued at
Cebu City on September 20, 2016.

____________________
NOTARY PUBLIC

Roll No. 1234

PTR No. 2345
CTC No. 53467
MCLE No. 25521