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Republic of the Philippines )

City of Cebu ) S.S

JACQUELINE GAVINO,
Complainant;

-vs- I.S. No. 12345


For: Qualified Theft

BELEN MEJARES Y VALENCIA,


Respondent.

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COMPLAINT- AFFIDAVIT

Complainant, JACQUELINE GAVINO, of legal age, married and a


resident of San Juan City, Philippines after being sworn in accordance
with law depose and say that;

1. I am filing a complaint for Qualified Theft against Ms. BELEN


MEJARES VALENCIA, herein referred to as respondent, of legal
age, and with residence at

2. On May 22, 2012 at around 1:00 p.m. My other household helper


Raquel Torres, was cleaning the dining area of our condominium
unit when she noticed that BELEN MEJARES VALENCIA’S
cellphone kept ringing. BELEN MEJARES VALENCIA answered it,
hurrying to the computer room and away from Torres. When
BELEN MEJARES VALENCIA returned, she was "pale, perspiring
and panicky." When Torres asked about the identity of the caller,
BELEN MEJARES VALENCIA did not answer. She told her instead
that I met an accident and instructed her to get something from
a drawer in the masters' bedroom. Since it was locked, BELEN
MEJARES VALENCIA was supposedly told to destroy it.

3. That accused BELEN MEJARES VALENCIA, single, of legal age,


Filipino citizen and a resident of Manila, Philippines where she
may be served with summons and other relative legal processes
thereto

4. That Raquel Torres added that when BELEN MEJARES VALENCIA


emerged from the bedroom, she was holding a plastic hamper
that contained a black wallet and envelopes and was talking with
someone on her cellphone. After a few minutes, BELEN MEJARES
VALENCIA informed her that I did not want other household
members to know what happened and that she was instructed to
also take a watch and jewelry, since the cash in the drawer was
not enough to pay the other driver in the accident who was
threatening to sue. Torres narrated that after preparing
everything, BELEN MEJARES VALENCIA left with a green bag

5. At around 5 o’clock in the afternoon, I tried calling but could not


access my household landline, so I decided to call Torres' cellular
phone to have her instruct the driver to pick her up from the
Movie and Television Review and Classification Board's Office.
After the phone call was cut, I then received a call from BELEN
MEJARES VALENCIA, informing me about what happened.

6. That BELEN MEJARES VALENCIA told me about receiving a call


from a certain Nancy, who stated that I wanted to avoid the
publicity that may arise from her supposed accident. BELEN
MEJARES VALENCIA thereafter claimed that she was instructed
to break the drawer in the masters' bedroom and to take all its
contents. However, I clarified in her account that she had neither
a personal secretary nor an aide named Nancy. I also affirmed
that I did not figure in any accident.

7. On May 22, 2012, Mr. Baluyot, my driver, claimed that BELEN


MEJARES VALENCIA told him to bring her to Greenhills Shopping
Mall, allegedly on my orders. He complied. He narrated that he
saw her carry a green bag. After dropping BELEN MEJARES
VALENCIA at the mall entrance, he returned to the
condominium. He added that when the incident was
subsequently being investigated, he heard the guards say that
they tried to stop BELEN MEJARES VALENCIA from leaving,
although she had told him that it was only Torres who was
stopped by the guards for not having a gate pass.

8. That on or about the 22nd day of May 2012, in the municipality


of the City of San Juan, Philippines and within the jurisdiction of
this Honorable Court, the said accused BELEN MEJARES
VALENCIA did there and then voluntarily, unlawfully, and
feloniously had, voluntarily, unlawfully committed the crime of
Qualified Theft punishable under Article 310 of the Revised Penal
Code

9. At around 1:30 p.m. Garcia, the Condo Guard, narrated that he


saw BELEN MEJARES VALENCIA about to leave the premises
carrying a green bag. However, he did not allow her to leave in
the absence of a gate pass signed by her employer. Despite his
insistence that BELEN MEJARES VALENCIA call her employer, she
did not. After a few moments, her cellphone rang. Instead of
answering Garcia's query on the caller's identity, BELEN MEJARES
VALENCIA rushed to the elevator. Afterwards, Garcia saw
Mejares leave using her employer's car driven by Baluyot.
According to him, he still attempted to stop them by warning
them that they could be victims of dugod ugo gang, to no avail.

10. That PO3 Clifford Hipolito testified that during the


investigation, he questioned BELEN MEJARES VALENCIA about
what happened. She stated that someone called her and
instructed her to destroy her employer's drawer, take the cash
and valuables there, and bring everything to Baclaran because I
had met an accident. When asked if she was aware of the
dugo-dugo gang, she answered that she was. PO3 Hipolito was
likewise informed that condominium security initially prevented
BELEN MEJARES VALENCIA from leaving but she went back to
the unit, refusing to call her employer.

11. I am executing this complaint-affidavit to attest to the truth


and veracity of the foregoing statements, to file a formal
complaint of QUALIFIED THEFT against BELEN MEJARES
VALENCIA and for any legal purposes it may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 22nd day


of May 2012 at City of San Juan, Philippines.

JACQUELINE GAVINO
Affiant

SUBSCRIBED AND SWORN to before me, this 22nd day of May 2012,
by JACQUELINE GAVINO who exhibited to me her Community Tax Certificate
No. 125698 issued at San Juan City, Philippines on 22nd of May 2021

ATTY. DEIRDRE TAALA


Counsel for the Plaintiff
PTR No. 2111816
IBP No. 86534323
Roll No. 34523
Room 24, J.J Building, San Juan City,Philippines

Notary Public
Doc. No. 57;
Page No. 11;
Book No. 04;
Series of 2012

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