Republic of the Philippines

Department of Justice
Region IV-A
OFFICE OF THE CITY PROSECUTOR
BATANGAS CITY
Brgy. Pallocan West, Batangas City

JUAN DE LA CRUZ, NPSD NO. ____________

Complainant,

Versus for

MARIA GIPIT, QUALIFIED THEFT.

Respondent.
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COMPLAINT-AFFIDAVIT

I, JUAN DE LA CRUZ, Filipino, of legal age, married and a

resident of C. Tirona St., Batangas City, after having been duly sworn
to in accordance with law hereby depose and state:

1. That I personally know Respondent MARIA GIPIT (Maria),

Filipino, of legal age, single and a resident of 22 Bolbok, Batangas
City, because she is my employee, a copy of my SSS Contributions
Payment Form is hereto attached as Annex “A”;

2. That I own the store with business name Juan Poultry Supply
situated at C. Tirona St., Batangas City, a copy of my BIR
Registration is hereto attached as Annex “B”;

3. That I came to know of the identity of the respondent

because I hired her as a cashier in my store on January 26, 2021;

4. That I have a regular customer in the name of Pedro Santos

(Pedro), Filipino, single, of legal age and resident of 123, Alalum, San
Pascual, Batangas;

5. That on October 13, 2021, I reviewed the purchase records

of Pedro and found that he had made purchases amounting to Five
Hundred Thirty Thousand Pesos (Php530,000.00), a copy of his
purchase records is hereto attached as Annex “C”;

6. That I also reviewed his payment records and found that he

had made payments amounting to Three Hundred Thirty Thousand
Pesos (Php330,000.00), a copy of his payment records is hereto
attached as Annex “D”;

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 7. That no additional payments were made which prompted me
to secure the services of Atty. Laika A. Hernandez for the preparation
of a demand letter to be sent to Pedro which he received also on
October 13, 2021;

8. That on October 14, 2021, Pedro personally went to my

office and brought an Official Receipt showing that he has paid the
amount of Four Hundred Thousand Pesos (Php400,000.00) on March
13, 2021, a copy of the said Official Receipt is hereto attached as
Annex “E”;

9. That I checked the duplicate copy of the Official Receipt in

my store and found out that the payment made on March 13, 2021
amounted to Two Hundred Thousand Pesos (Php200,000.00) only, a
copy of the duplicate Official Receipt is hereto attached as Annex
“F”;

10. That the person who received the money and who issued
the Official Receipt to Pedro is no other than Maria, the cashier in my
store, as evidenced by her signature therein;

11. That based on my records, there was still an outstanding

balance of Pedro in the amount of Two Hundred Thousand Pesos
(Php200,000.00) despite the fact that he even made an overpayment
on March 13, 2021;

12. That I asked Maria regarding the discrepancy in the balance

of Pedro despite the payment that he made, and the amount that she
collected from him but she failed to give any explanation thereto;

13. That based on Maria’s actions, she took the Two Hundred
Thousand Pesos (Php200,000.00) for herself instead of safe-keeping
it in my store since it was a payment of Pedro for his obligations to
my store;

14. That being an employee and cashier in my store, I fully

entrusted Maria that she would carry out her duties and
responsibilities as a cashier in an honest manner but clearly, she
failed to do so;

15. That I am executing this Affidavit to attest to the truth of the

foregoing statements, and to charge Respondent MARIA GIPIT for
the offense of QUALIFIED THEFT defined and penalized under Art.
310 in relation to Art. 308 of the Revised Penal Code.

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 IN WITNESS WHEREOF, I hereunto set my hand this 15 th day
of November, 2021 in Batangas City.

JUAN DE LA CRUZ
Plaintiff

SUBSCRIBED AND SWORN TO before me this 15th day of

November, 2021 in Batangas City.

RUTH ADELAIDA
Administering Officer

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