Republic of the Philippines)

City of Tagbilaran)S.S.
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COMPLAINT AFFIDAVIT

Name of Witness: GALILEO N. ENAD SR.

Address: Maguikay, Mandaue City

Name of Lawyer who conducted the Examination: Atty. Francis George

F. Dinopol
Place: Suite 402 G.K. Chua Bldg., Sancianco St., Cebu City

I, GALILEO N. ENAD SR, of legal age, Filipino, and a resident

of Pajac, Lapu-Lapu City, after having been duly sworn to in
accordance with law, do hereby depose and say:

Atty. Dinopol:
1. Q: Do you know a certain ISIDRO M. TALIP, JR?
A: Yes.

2. Q: Why do you know him?

A: Because he used to be a Collector of Solid Motorcycle
Distributors, Inc.

3. Q: This Collector of Solid Motorcycle Distributors, Inc., what is

main line of business?
A: Selling of motorcycle and motorcycle parts.

4. Q: And, as you said earlier, ISIDRO M. TALIP, JR formerly was

a Collector of Solid Motorcycle Distributors, Inc., is that correct?
A. Yes.

5. Q: How about you, how are you connected with Solid

Motorcycle Distributors, Inc?
A: I am an Auditor of Solid Motorcycle Distributors, Inc.
6. Q: So in other words, ISIDRO M. TALIP, JR. is no longer a
collector of Solid Motorcycle Distributors, Inc., how come?
A: He resigned from his employment. It was because we
discovered several anomalies on his job as a Collector, we received
several complaints from customers about payments they made
through PALAWAN EXPRESS PERA PADALA which were not
remitted to the cashier of Solid Motorcycle Distributors, Inc.

7. Q: Can you describe ISIDRO M. TALIP, JR.’s duties and

responsibilities as a collector of Solid Motorcycle Distributors, Inc.?
A: His duties, among others, is to receive payments from the
customers of Solid Motorcycle Distributors, Inc., to make follow-ups
to delinquents customers, the money he receives from the customers,
he has to remit them to the cashier of Solid Motorcycle Distributors,
Inc.

8. Q: With respect to ISIDRO M. TALIP, JR, where is the branch

manager concerned of Solid Motorcycle Distributors, Inc. located?
A: At Solid Motorcycle Distributors, Inc. Tagbilaran Branch in,
Purok 4, Dao District, Tagbilaran City, Bohol.

9. Q: You said earlier, that ISIDRO M. TALIP, JR received

payments from several customers of Solid Motorcycle Distributors,
Inc., through PALAWAN EXPRESS PERA PADALA but said
payments were never remitted, what did your superiors do?
A: I was ordered by my superiors so conduct an investigation
and to contact the concerned customers.

10. Q: So were you, in fact, able to conduct the concerned

customers?
A: Yes.

11. Q: What was the result of the investigation?

A: I prepared a Report, here it is.

Atty. Dinopol:

The witness presented to me the SMDI-TAGBILARAN TRIP

REPORT dated October 10, 2017 hereto attached as Annex “A”.

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12. Q: I am going over this Report dated October 10, 2017, and it
says here in item number 1 that ISIDRO M. TALIP, JR. received from
a customer named O. Betonio, S. Villarejo, and J. Manos, on several
occasions, is that correct?
A: Yes.

13. Q: With respect to this O. Betonio, which, according to your

report, paid to ISIDRO M. TALIP, JR, on the following dates: March
1, 2017, May 4, 2017, April 1, 2017, June 1, 2017, and July 2, 2017, do
you have any evidence of these payments through Palawan Express
Pera Padala?
A: Yes, here they are.

Atty. Dinopol:
The witness presented to me:
-Palawan Express Pera Padala dated March 1, 2017, Transaction
Code: BFD-10-29972-ZAW, hereto attached and marked as Annex
“B”;
-Palawan Express Pera Padala dated April 1, 2017, Transaction
Code: DBW-8-11365-ZAW hereto attached and marked as Annex “B-
1”;
-Palawan Express Pera Padala dated May 4, 2017, Transaction
Code: BFD-10-43968-ZAW hereto attached and marked as Annex “B-
2”;
-Palawan Express Pera Padala dated June 1, 2017, Transaction
Code: BFD-10-49893-ZAW hereto attached and marked as Annex “B-
3”; and
-Palawan Express Pera Padala dated July 1, 2017, Transaction
Code: BVZ-9-3436-ZAW hereto attached and marked as Annex “B-4”;

14. Q: Also in item 1 of your report dated October 10, 2017, it says
here that a certain S. Villorejo paid to Isidro. Talip Jr., on June 2, 2017,
through Palawan Express Pera Padala, do you have any evidence of
this payment through Palawan Express Pera Padala?

A: Yes, here it Is, the payment was made by Susan L. Villorejo,

Richard Villorejo’s wife.
Atty. Dinopol:

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 The witness presented to me Palawan Express Pera Padala send
money form dated June 2, 2017, Transaction Code: ANN-10-2083-
ZAW, hereto attached and marked as Annex “C”;

15. Q: Also in item 1 of your report dated October 10, 2017, it says
here that a certain J. Manos paid to Isidro. Talip Jr., on July, 24, 2017
and September 9, 2017, through Palawan Express Pera Padala, do
you have any evidence of these payment through Palawan Express
Pera Padala?

A: Yes, here it is.

Atty. Dinopol:
The witness presented to me a letter dated September 28, 2017
executed bt Eustiquio B. Bohol, Jr of, Head of Customer Case
Division of Palawan Pawnshop, hereto attached and marked as
Annex “D”;

16. Q: Mr. Witness, according to the receipts “Annex “B” to Annex

“B-4”, Mr. Onofre Betonio III paid to Isidro M. Talip, Jr. in the
following manner:
a. P4,000.00 on March 1, 2017 (Annex “B”)
b. P2,830.00 on April 1, 2017 (Annex “B-1”);
c. P2,000.00 on May 4, 2017 (Annex B-2);
d. P3,000.00 on June 1, 2017 (Annex “B-3”; and
e. P2,900.00 on July 2, 2017 (Annex B-4);
- were they all remitted to the cashier of Solid Motorcycle
Distributors, Inc.?

A: Three (3) of those payments were under-remitted (meaning

Mr. Talip, Jr. only remitted partially what he had received that day
from Mr. Betonio, and the rest were not remitted at all.
I have here the Collection receipt No. 20416 which clearly states
that Mr. Talip, Jr. only remitted P3,630.00 instead of the P4,000.00 he
received from Mr. Betonio that day, the difference of P370.00, is
clearly pocketed by Mr. Talip, Jr.
I have here the Collection receipt No. 23857 which clearly states
that Mr. Talip, Jr. only remitted P1,500.00 instead of the P2,000.00 he
received from Mr. Betonio that day., the difference of P500.00, is
clearly pocketed by Mr. Talip, Jr.

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 Also, I have here the provisional receipt (Office Copy) No.
0034711 which clearly states that Mr. Talip, Jr. only remitted
P3,000.00 instead of the P4,000.00 he received from Mr. Betonio that
day, the difference of P1,000.00, is clearly pocketed by Mr. Talip, Jr.
-All the other payments were never remitted at all.

Atty. Dinopol:
The witness presented to me:

a. Collection receipt No. 20416, hereto marked as Annex “B-5”;

b. Collection receipt No. 23857, hereto marked as Annex “B-6”;
and
c. provisional receipt (Office Copy) No. 0034711, hereto marked
as Annex “B-7”;

17. Q: So, according to item 1 of your report, the payments made

by O. Vellarejo and J. Manos, were never remitted, is that correct.
A: They were never remitted.

18. Q: With respect to item 1 of your report, as far as payments made

trough Palawan Express Pera Padala, how much was the total
amount of money that was not remitted by Mr. Talip, Jr.?
A: P12,700.00

19. Q: We go now to item 2 of your report, you declared that a total

P20,229 were not issued with company’s official receipt, can you
elaborate on this?
A: Yes. These were payments made by customers J. Manos, D.
Arelalejo, R. Gumanid, C. Estillore and J. Bacquero but were not
issued with corresponding official receipts, and they were never
remitted to the cashier of Solid Motorcycle Distributors, Inc.
Tagbilaran Branch in, Purok 4, Dao District, Tagbilaran City, Bohol.

20. Q: How did you come up with this declaration?

A: I interviewed the customers and then after that, they

executed affidavits. I have here the affidavits.

Atty. Dinopol:

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 Q: The witness presented to me the affidavit of Jobel Manos,
hereto attached as Annex “E”; affidavit of Dimple Arlalejo, hereto
attached as Annex “F”; Affidavit of Roque L. Gumanid, hereto
attached as Annex “G”; Affidavit of Catherine M. Estillore, hereto
attached as Annex “H”, and affidavit of Jesus L. Baquero, hereto
attached as Annex “I”.

21. Q: Mr. Witness, I am going over the affidavit of Jobel D. Manos,

wherein he alleged that:
a. on June 15, 2017, he paid to Mr. Talip, Jr. the amount of
P2,300.00;
b. on July 30, 2017, he paid to Mr. Isidro Talip, Jr. the sum of
P2,929.00; and
c. on August 25, 2017, he paid to Mr. Isidro Talip, Jr. the sum of
P3,000.00
-and Mr. Isidro Talip, Jr. did not issue receipts for the same and
neither did Mr. Talip, Jr. remitted the same to the cashier of Solid
Motorcycle Distributors, Inc. Tagbilaran Branch in, Purok 4, Dao
District, Tagbilaran City, Bohol, is that correct?
A: That is correct.

22. Q: Mr. Witness, I am going over the affidavit of Dimple B.

Arlalejo, wherein she alleged that on August 20, 2017, she paid to Mr.
Talip, Jr. the amount of P3,000.00 but Mr. Isidro Talip, Jr. did not
issue receipt for the same and neither did Mr. Talip, Jr. remitted the
same to the cashier of Solid Motorcycle Distributors, Inc. Tagbilaran
Branch in, Purok 4, Dao District, Tagbilaran City, Bohol, is that
correct?
A: That is correct.

22. Q: Mr. Witness, I am going over the affidavit of Roque L.

Gumanid, wherein he alleged that:
a. on August 18, 2017, he paid to Mr. Talip, Jr. the amount of
P1,000.00; and
b. on September 3, 2017, he paid to Mr. Isidro Talip, Jr. the sum
of P1,500.00;
-and Mr. Isidro Talip, Jr. did not issue receipts for the same and
neither did Mr. Talip, Jr. remitted the same to the cashier of Solid
Motorcycle Distributors, Inc. Tagbilaran Branch in, Purok 4, Dao
District, Tagbilaran City, Bohol, is that correct?
A: That is correct.

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 23. Q: Mr. Witness, I am going over the affidavit of Catherine
M. Estillore, wherein she alleged that on September 6, 2017, she paid
to Mr. Talip, Jr. the amount of P1,000.00 and Mr. Isidro Talip, Jr. did
not issue receipt for the same and neither did Mr. Talip, Jr. remitted
the same to the cashier of Solid Motorcycle Distributors, Inc.
Tagbilaran Branch in, Purok 4, Dao District, Tagbilaran City, Bohol, is
that correct?
A: That is correct.

24. Q: Mr. Witness, I am going over the affidavit of Jesus L.

Baquero, wherein he alleged that on August 12, 2017, he paid to Mr.
Talip, Jr. the amount of P5,500.00 and Mr. Isidro Talip, Jr. did not
issue receipts for the same and neither did Mr. Talip, Jr. remitted the
same to the cashier of Solid Motorcycle Distributors, Inc. Tagbilaran
Branch in, Purok 4, Dao District, Tagbilaran City, Bohol, is that
correct?
A: That is correct.

25. Q: So, all in all, as far as item 2 of your report, the total
collections made by Mr. Isidro Talip, Jr. for which he did not issue
receipts for the same and neither did he remitted the said payments
to the cashier of Solid Motorcycle Distributors, Inc. Tagbilaran Branch
in, Purok 4, Dao District, Tagbilaran City, Bohol, is in the amount of
P20,229.00, is that correct?
A: That is correct.

26. Q: Did Solid Motorcycle Distributors, Inc. make any

demands to Mr. Isidro Talip, Jr.?

A. We sent two (2) demand letters, the first one id dated

September 9, 2017 and the second one is dated September 25, 2017, I
have here the copy.

Atty. Dinopol:

The witness presented to me Demand Notice dated September 9,

2017, a copy of which is hereto attached as Annex “J”, and demand
letter dated September 25, 2017, hereto attached as Annex “K”.

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27. Q: Were you able to send the demand letter?
A: Yes, actually, both letter were personally received by Mr. Talip, Jr.

28. Q: How much was the actual amount that was not remitted by
Mr. Isidro Talip Jr.?
A: The sum of P32,929.00.

29. Q: Solid Motorcycle Distributors, Inc., admittedly is a

corporation, are you duly authorized to file this instant complaint?
A: Yes, I have a copy of the Secretary’s Certificate.

Atty. Dinopol:
The witness presented to Secretary’s Certificate, machine copy of
which is hereto attached as Annex “L”;

30. Q: Did Mr. Talip, Jr. comply with the demand notice?
A: No.

I execute this affidavit to attest to the truth of the foregoing and

to support my complaint against Isidro M. Talip, Jr. for Estafa and/or
Qualified Theft.

IN WITNESS WHEREOF, I have hereunto set my hand this ___

day of November, 2017 at Tagbilaran City, Bohol, Philippines.

GALILEO N. ENAD, SR.

Affiant

SUBSCRIBED AND SWORN to before me this __ Day of

November, 2015 in the City of Tagbilaran, Province of Bohol. I
hereby certify that the witness is answering the questions asked
before him, fully conscious that she does so under oath and that he
may face criminal liability for false testimony of perjury.

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Republic of the Philippines)
City of Cebu)S.S.
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SWORN ATTESTATION
That I, Francis George F. Dinopol with office address at Room
402 G.K. Chua Building, Sancianco St., Cebu City, after having been
duly sworn to in accordance with law do hereby depose and say:
1. That I am the lawyer who conducted the examination of
Galileo N. Enad Sr.
2. That I faithfully recorded or caused to be recorded the
questions I asked and the corresponding answers that the witness
gave;
3. That neither I nor any other person then present or assisting
me coached the witness regarding the answers of the witness.
4. That I execute the affidavit to attest the truth of the foregoing
and for whatever purpose it may serve.
IN WITNESS WHEREOF, I have hereunto affixed my signature
this ___ day of November 2017 at Cebu City, Philippines.

FRANCIS GEORGE F. DINOPOL

Affiant

SUBSCRIBED AND SWORN to before me this ___ Day of

November 2017, at Cebu City, affiant exhibited to me his Driver’s
License No. GO1-00-262953 as competent proof of identity.
Doc. No. ____
Page No. ___
Book No. ____
Series of 2017

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