REPUBLIC OF THE PHILIPPINES)

City of Manila ) S.S.

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COMPLAINT-AFFIDAVIT

I, Earica Silla, of legal age, single, Filipino, and a resident of Unit 1213 Laperal
Apartment, Recto Avenue, Manila City, Metro Manila, Philippines, after having been duly
sworn to according to law hereby depose and say that:

a. The accused is Cherly Bugarin, of legal age, Filipino, and a resident of 812
Recto Avenue, Manila City, Metro Manila, Philippines;
b. That I am the employer of Cherly Bugarin who has been my personal
maid for 5 years. I entrusted the key to my master’s bedroom to her,
with confidence, for daily cleaning;
c. That on June 10, 2019, in the early afternoon, while I was at work, I
could not access my household landline past 5:00 p.m., so I decided to
call my driver, Alyssa Alonzo’s, cellular phone to instruct her to pick me up at
the Movie and Television Review Board’s Office;
d. That after the phone call was cut, I received a call from Bugarin,
informing me that she received a call from a certain Nancy, who
represented herself as my assistant;
e. That Nancy told her that I met an accident and that I wanted to avoid the
publicity that may arise from the supposed accident;
f. That Bugarin claimed that she was instructed by Nancy to unlock the
drawer in the master’s bedroom and to take all its contents to which she
has access in order to pay for the damages to the other driver who was
threatening to sue;
g. That I was neither in an accident nor do I have a personal secretary or aide
with the name of Nancy;
h. That I was later informed by my driver, Alonzo that Burgarin asked her to drive
 for her going to Greenhill’s Shopping Center allegedly on my direction, as
narrated in her own Witness Affidavit herein attached as ANNEX A;
i. That at that time, Bugarin was acting suspicious and that she was then
carrying a green bag;
j. That due to the said incident, I suffered damages when I lost the following
items, to wit:

Rolex wrist watch - Php 400,000

Cash money - Php 50,000

with the total amount of Php 450,000.00. (Documented as ANNEX B-1 and
ANNEX B-2)

k. Upon consultation with my lawyer, I understand that the acts of the accused
constitute QUALIFIED THEFT punishable under Article 310 of the Revised
Penal Code;
l. Article 310 of the Revised Penal Code provides that: Qualified theft. — The
crime of theft shall be punished by the penalties next higher by two degrees
than those respectively specified in the next preceding article, if committed
by a domestic servant, or with grave abuse of confidence, or if the property
stolen is motor vehicle, mail matter or large cattle or consists of coconuts
taken from the premises of a plantation, fish taken from a fishpond or fishery
or if property is taken on the occasion of fire, earthquake, typhoon, volcanic
eruption, or any other calamity, vehicular accident or civil disturbance.”
m. I am executing this affidavit to attest to the truth of the foregoing facts and
for the purpose of filing a criminal complaint for QUALIFIED THEFT against the
accused.

IN WITNESS WHEREOF, I have hereunto set my hand this 20 day of June 2019 at Manila
City, Metro Manila, Philippines.

EARICA SILLA
Complainant

SUBSCRIBED AND SWORN TO before me this 20th day of June 2019 at City of Manila,
Philippines, affiant exhibiting to me her Government issued passport, with passport no. AB12345
being sufficient and competent evidence of her identity.
 ATTY. JAN CARLOU TIRATIRA

Assistant City Prosecutor

Doc. No. _____;

Page No. _____;

Book No. _____;

Series of 2019.