Republic of the Philippines)

City of Davao ) S.S.

x--------------------x

COMPLAINT

The complainant, Carlo Cruz, accuses Ana Lu and Elizabeth

Lu, of QUALIFIED THEFT, and respectfully avers that:

1. Carlo Cruz is the lawful owner of a Shopping Mall,

operating under the name of “CC Mall” located at Bajada,
Davao City;

2. Ana Lu was hired by the complainant in January 2018 as

Operations Supervisor, being experienced on such
function with commendable academic records. She was
even indorsed for hiring by Carlo Cruz’s mother;

3. Inherent to his position, Ana Lu has access to the various

department and store rooms where articles, materials, and
supplies of the said mall were stored. Thus, her
designation was impressed with the owner’s confidence;

4. On 1st day of March, 2019, Ana Lu, did then and there
willfully and feloniously, with grave abuse of confidence,
with intent to gain and without the consent of the owner
thereof, take, steal, and carry away from the said mall,
P100,000.00 cash collections for the day and 2 units
Lenovo Laptops valued at P40,000.00 each, to the damage
and prejudice of CC Mall and its owner Carlo Cruz;

5. Elizabeth Lu was the cousin of Ana Lu, currently

employed at the Landbank of the Philippines, Bajada
Branch, Davao City;

6. Without having participated in said crime either as

principal or accomplice, Elizabeth Lu, then and there
unlawfully take part subsequent to its commission by
profiting herself and assisting accused Ana Lu to profit by
the effect of the crime, by then and there buying the said
laptops from Ana Lu, knowing that they had been stolen.

Page 1 of 4
 Davao City, this 2nd day of March, 2019.

CARLO CRUZ
Complainant/Offended Party

WITNESSES:

________________________

________________________

SUBSCRIBED AND SWORN TO before me this 2nd day of

March 2019 in Davao City, affiant exhibited to me his SSS
Identification Card No. 1234 issued on April 5, 2017 in Davao City.

WITNESS MY HAND AND SEAL.

NOTARY PUBLIC

TRRU LAW OFFICE

Counsel for Defendant
Dr. 2 Esperanza Bldg., 198 Tulip Drive, Ecoland, Matina, Davao City
Tel. +6382 2412941. Mob. +639322984878; Email. trrulawoffice@gmail.com
By:

ELLAN GET N. TINGSON

Roll of Attorneys 2017300373
MCLE Compliance III-0000001
PTR OR No. 123456B; 06/05/2018; Davao City
IBP OR No. 002076; 05/19/2021; Davao City

EDITHA L. ROXAS
Roll of Attorneys 2018400062
MCLE Compliance V-001221; 5/4/2018; Davao City
PTR OR No. 5392795; 7/8/2018; Davao City
IBP OR No. 00333

Page 2 of 4
 FAITH IMEE D. ROBLE
Roll of Attorneys 2018400057
MCLE Compliance V-0021173; 5/4/2018
PTR OR No. 123465; 1/4/2018; Davao City
IBP OR No. 00233

HANNA-TUNISIA F. USMAN
Roll of Attorneys 2018400036
MCLE Compliance V-0021116; 5/4/2018
PTR OR No. 0000000A; 1/1/2018; Davao City
IBP OR No. 000001

Republic of the Philippines)

Davao City )S.S.

AFFIDAVIT OF SERVICE

I, Ne Mo, as Legal Assistant of the TRRU Law Office, with address at Dr. 2
Esperanza Bldg., 198 Tulip Drive, Ecoland, Matina, Davao City, under oath depose
and say:

On 18thday of February 2019, I filed with the Honorable Court and served a
copy of the following pleading/paper:

ANSWER TO THE COMPLAINT

WITH COUNTERCLAIM

Page 3 of 4
On the other party in Civil Case No. R-DVO-29-2019-CV, for Recovery of parcel of
land and building (Accion Publiciana) on expired lease, Spange Bab, plaintiff, vs.
Squid Ward, respondents, pursuant to Rule 13 of the Rules of Court:

By personal Service:

SPANGE BAB
Plaintiff
Block 32 Lot 31 Clarity Street
Pag Ibig Homes, Buhangin Davao City,
Davao Occidental, Philippines
Received by: ___________________
Date: __ February 2019

JEDAIDAH V. LIBRES
Affiant

SUBSCRIBED AND SWORN to before me this 18th day of February 2019 in

Davao City, Philippines, affiant exhibiting to me her BIR TIN 444-555-661, as
competent proof of identity.

Doc. No. __;

Page No.__;
Book No. I;
Series of 2019.

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