(REPUBLIC OF THE PHILIPPINES)

(CITY OF DAVAO) S.S.

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AFFIDAVIT-COMPLAINT

I, PALITO PALITO, of legal age, Filipino, married with

business address at 25 Madrigal Avenue, Davao 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, Davao City;

2. After having duly sworn to in accordance with law, I do

hereby accuse PANCIT CANTON, 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 2018 to FEBRUARY 2019 was committed in Davao
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 PANCIT CANTON 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 2018, I received verbal reports from

MARIO LUIGI, Branch Accountant about the
inconsistencies in the sales report despite the good sales
performance of the Alabang branch;
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3.5 Acting on the Information that I received from MARIO

LUIGI, an audit team spearheaded by MARIO LUIGI
was formed to conduct a thorough examination of the
sales and sales report made of respondent as branch
cashier from June 2014 to February 2019;

3.6 Based on the Audit Report submitted by MARIO

LUIGI, the following were the findings to wit:

A) “Upon further checking by the

undersigned (MARIO LUIGI) of PANCIT
CANTON’S 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 2018 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 2019, 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
corporation’s 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.
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7. Respondent’s 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 Davao 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.

(SGD.) PALITO PALITO

Affiant

SUBSCRIBED AND SWORN TO ME THIS 19th day of September 2019

in the City of Davao, Philippines. I hereby certify that I personally examined
the affiant and I am convinced that he voluntarily executed and fully
understood the contents of his affidavit.

(SGD.) Marimar May Amoy

Senior Assistant City prosecutor
Davao City