Republic of the Philippines

Third Judicial Region

Regional Trial Court
Branch 66 Capas, Tarlac

People of the Philippines

Criminal Case No. CT18-7031
- vs. –
For: Qualified Theft
James Vandine y Dela Cruz
x---------------------------------x

Stipulation of Facts:

1. That the accused is an employee of a trucking company which Ebon Agro

Industrial Corporation (Ebon for brevity) employed for the transport of its
products at the time the act complained of took place.
2. That as the driver, the work designated to the accused is to transport Ebon’s goods
from one place to another without any deficiency in their number.
3. That on or about 4:00 in the afternoon of February 2, 2018, while transporting the
feeds bought by Ebon from GR8 Multi-Purpose Cooperative (GR8 for brevity) the
accused was caught unloading three (3) sacks of feeds.
4. That after unloading the three (3) sacks of feeds, he sold the same to a tricycle
driver.
5. That after selling the sacks of feeds to the tricycle driver, the sacks of feeds were
loaded to the tricycle and then the tricycle left immediately.
6. That when the truck arrived at Ebon Farm, the employees of Ebon conducted an
inventory to verify if the products’ weight at the time they left the premises of
GR8 is still the same when they reached Ebon Farm. To this end, Ebon’s
employees found out that there is a deficiency in the quantity of feeds so delivered.
7. That during the inventory made by the employees of Ebon, the accused
immediately left the premises.
8. That when the accused was invited by the police and the other employees of Ebon
for investigation, the accused admitted that he authored the act complained of.

Issue: Whether or not the accused is criminally and civilly liable?

Witnesses to be Presented:

1. Servillano Valdez Bermudo

2. Abegail Garcia Madriaga
3. SPO1 Aladin B. Ao-as

The plaintiff reserves the right to present additional witnesses as the need arises.

Documentary Evidence:

1. Spot Report dated February 2, 2018 made by the Philippine National Police Capas
Station, Capas, Tarlac.

The plaintiff reserves the right to present additional documentary evidence as the need
arises.