Republic of the Philippines}

City of Davao }S.S

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

AFFIDAVIT-COMPLAINT

I, JOHN DOE, of legal age, Filipino, married, with residence address at MAKATI
City, Philippines, after having been duly sworn in accordance with law, do hereby
depose and state, that:

1. I am the authorized representative of XXXXXXXX a corporation duly organized

and existing under the laws of the Republic of the Philippines which can be
served with notices, processes, and orders of this Honorable Office at its
principal address at XXXXXXXX, Philippines, as evidenced by a Secretary’s
Certificate herein attached and marked as Annex “A”;
2. As such, I have personal knowledge of the day-to-day transactions of the
Corporation. I knew of the employees working therein one of which is the
person of XXXXXXXX, who was designated as a Head Office (H.O.) Auditor
and was in-charge with the branch expansion of the Lending Department in
different branches within Luzon area. Attached herewith is a copy of the
Social Security System summary contribution of Davao Central Warehouse
Club, Inc., depicting the name XXXXXXXXX as proof that he was an employee
thereof, marked as Annex “B”;
3. On several occasions, the said employee Mr. Norberto Ayala did not remit
and failed to return the excess payments for the budget expansion for the
different branches of its Lending Department. I have caused the matter to be
reported to the other H.O. Auditor as per advice of the management;
4. On July, 12, 2011, an audit team was tasked to look into and investigate the
matter regarding Mr. Norberto Ayala. Said audit was conducted by the other
Head Office Auditor of the company in the persons of Mr. Ray M.
Reambonanza and Richard Baldelovar where the extent of Mr. Norberto
Ayala’s anomalies and fraudulent transactions was discovered; Attached
herewith is the Audit report marked as Annex “C”;
5. Validated by the examination report, Mr. Norberto Ayala was terminated
from the company on February 15, 2011. Attached herewith is a copy of the
Final Notice of Dismissal marked as Annex “D”;
6. The acts complained of were committed as follows:

a. On various dates, beginning from 2009 until 2010, said Mr. Norberto
Ayala, Auditor-in-Charge for the expansion of different branches of
the Lending Department received and/or collected cash representing
payments for the said expansion project. As per company practice,
Mr. Alvin Congmon will request the budget to the management and
once approved, the company will send the money directly to Mr.
 Norberto Ayala through bank transactions for him to purchase the
items as specified in the request pursuant to the expansion project;
b. However, Mr. Norberto Ayala failed to return to the company the
excess of the expenses for the expansion, to wit:

7. I am executing this Affidavit-Complaint to attest to the truthfulness of the

foregoing facts, and to inform the proper authorities especially the City
Prosecutions Office in order to file a criminal charge against XXXXXXXXXX,
who may be served with summons notices and processes of this Honorable
Office at, Davao City, for violation of Article 315 par 1(b) of the Revised
Penal Code or ESTAFA, or such other criminal action deemed fit and proper
under the premises.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 17 th day of September

2012, in Davao City, Philippines.

______________
Affiant

SUBSCRIBED AND SWORN to before me, this 17th day of September 2012 in
Davao City, Philippines. I hereby certify that I have personally examined the affiant and
that I am fully satisfied that the foregoing declarations were made by him freely and
voluntarily and that he fully understood the same.

Doc No. ____

Page No.____
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Series of 2012.