[Republic of the Philippines]

[City of Zamboanga] S.S

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AFFIDAVIT OF COMPLAINT
I, MARIA DELFINA R. INSON, of legal age, married and a
resident of Rosa Village, Pasonanca, Zamboanga
City, Philippines, with a business address at
Isabela City, Basilan Province. It is duly licensed
corporation and operating under Business Permit No.
055 issued by the City Mayor for this year 2016,
said business Permit is attached herewith as ANNEX
“A”, after having been duly sworn to in accordance
with law, do hereby depose and say that:

1. That I personally know MARVIN T. EUPINADO, of

legal age , single and a resident of La Piedad,
Isabela City, Basilan, Because he is an employee of
the corporation assigned at its branch in Curuan,
Zamboanga City, his job description in the
corporation is to appraise the items that sought to
be pawned, and he recommend for the appraise value
of the item and he also has an access to the vault
wherein the pawned items are being stored, and
certain amount of money use in the day to day
operation of the pawnshop;

2. That the corporation conducted inventory and audit

in Curuan Branch, Zamboanga City, where Marvin T.
Eupinado is assigned, the audit was under-taken by
GERARDO F. IGIDO and JOHN MARK M. FERNANDO, both
are not only bookkeepers that conducts inventory
but also performs other task assigned to them, a
copy of the inventory is attached herewith as
“ANNEX B”

3. That on 15th of July 2016, they made the inventory

and audit and in the course thereof, they
discovered that the pawn tickets and the items
pawned did not match, there are also missing,
undetermined pawned items stored inside the vault;

4. That in the preparation of GERARDO F. IGIDO and

JOHN MARK M. FERNANDO of their report covering the
month of January to July, it was indicated therein
 the total shortage of FOUR HUNDRED TWELVE THOUSAND
THREE HUNDRED SIXTY FOUR (412,364.00) Pesos, where
there were also a number of items where described
in the pawn tickets as well as stubs relative to
the weight, description, and amount, that do not
match or coincide;

5. That the inventory prepared by Mr. Igido and

Fernando was used to file a case to the latter in
Curuan police station, where we came up to an
agreement that he will just pay us 6,000.00 a
salary deduction until the full payment and a down
payment of 40,000.00 to be financed by the older
sister who is working abroad, a copy of the
agreement is attached herewith as ANNEX “C”;

6. That after the agreement, Mr. EUPINADO is

reassigned in R.T. LIM, Surabay Zamboanga Sibugay,
but did not go to his assign branch, instead he run
away with the office supplies, including the radio,
I together with the other staffs of Zamboanga
branch looked for him and made a communication as
to his whereabouts but failed to locate the same, I
even reached out to his family about the incident
but to no avail;

7. That he is the only one trusted by me in carrying

out the day to day business operation of the said
branch and that he has the access to the vault
where he keeps the key with him , he also has the
opportunity to steal the missing pawn items inside
the vault and addition to this he also change the
names, value and weight and pawned in an over
appraised value in order to steal money and he did
all these for quite sometimes already;

8. That Marvin clearly abused and betrayed the trust

and confidence given to him by the corporation, he
also deceived the corporation not only by making
it appear that the names, appraised value, grams of
the jewelries were correct and also by over
appraised the value in order to get money from the
corporation in the amount stated in the inventory
and audit report;
9. That the GOLD & PRISM PAWNSHOP, INC. suffered
several losses already from accounts, thus we
cannot afford or bear any more losses. Thus, the
corporation is now suffering financial damages due
to the Fictitious name in the pawn tickets,
tampered receipts missing stubs, items and money
that Marvin took from the corporation in the amount
of FOUR HUNDRED TWELVE THOUSAND THREE HUNDRED SIXTY
FOUR (412,364.00) Pesos;

10. That, I execute this affidavit of complaint in

order to file criminal charges against MARVIN T.
EUPINADO, and I attest to the truth of the
foregoing statements.

That in view of the fact

AFFIANT FURTHER SAYETH NAUGHT

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

this ____________________in the City of Zamboanga,
Philippines.

MARIA DELFINA R. INSON

Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, a Notary Public in

and for Zamboanga City this ____ day of December,
2016. Affiant personally came and avowed under
penalty of law to the whole truth of the contents
of said instrument.

CERTIFICATION

THIS IS TO CERTIFY that I have personally examined the

herein affiant and that I am fully satisfied that
they voluntarily executed this affidavit and
understood the contents thereof.
[Republic of the Philippines]
[City of Zamboanga ] S.S
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JOINT AFFIDAVIT OF WITNESSES

We, JOHN MARK M. FERNANDO and GERARDO F. EGIDO, both of

legal age, single, Filipino and a resident A & W
Subdivision Guiwan, Zamboanga City, and Rosa Village,
Pasonanca, Zamboanga City, Philippines, after being
sworn in accordance with law, dispose and declare:

1.That we are both employees of Gold and Prism

Incorporated, doing business in Zamboanga City and
Isabela City, Basilan. I, JOHN MARK M. FERNANDO is
an appraiser of Gold and Prism, Mercado Branch in
Zamboanga City; while I, GERADO F. EGIDO, is the
bookkeeper and I also perform other task assigned
to me by my employer;

2. That we were task by our Corporate Manager, Ma.

Delfina R. Inson, to conduct inventory and audit at
Gold and Prism pawnshop, in Curuan Branch Zamboanga
City, with all the pawned items and jewelries in
the vault; that we did our assigned task and in the
course thereof, we discovered that there are
significant numbers of pawn tickets where tampered
and then items were overly appraised, but there
were also pawn tickets and stub which are genuine
but the items are no longer inside the vault and
are missing;

3.That there are also number of pawn tickets, where

the description of pawn items did not match with
those indicated and likewise described in the pawn
stubs, and these we referred to as undetermined
jewelry items because of the difficulty in the
inventory and auditing the same given the
unexplainable discrepancy of the data appearing in
both the pawn tickets and stubs;

4.That after the final inventory and auditing, we

prepared the inventory report where we clearly
indicated and listed all the tampered stubs,
receipts and items, undetermined items those that
were missing, and we also indicated the total value
of the inventory amounting to Two hundred Forty
 Thousand (240,000.00) pesos, a copy of the
inventory of Curuan Branch is attached herewith as
ANNEX “A”;

5.And in addition, we also discovered discrepancy in

the actual inventory and those appearing in the
Record book of the Corporation, there were separate
inventory report regarding the tampered stubs and
receipts and items, undetermined items and those
missing items that was pawned, the copy of the
inventory report and pawn tickets is herewith
attached as ANNEX “C” and “D”;

6. That, we execute this Joint-Affidavit to attest

to the truth of the foregoing statements and
declarations;

That in view of the fact

AFFIANT FURTHER SAYETH NAUGHT

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

this ____________________in the City of Zamboanga,
Philippines.

JOHN MARK M. FERNANDO GERARDO F. EGIDO

Affiant Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, a Notary Public in

and for Zamboanga City this __________th day of December,
2016. Affiant personally came and vowed under penalty of
law to the whole truth of the content of said instrument.
 CERTIFICATION

THIS IS TO CERTIFY that I have personally examined the

herein affiant and that I am fully satisfied that
they voluntarily executed this affidavit and
understood the contents thereof.

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2016.