Republic of the Philippines

Department of Justice
OFFICE OF THE CITY PROSECUTOR
Ilagan City, Isabela

TALAVERA HYPERMART, INC.,

Complainant,
NPS Docket No. ____________
Vs. For: QUALIFIED THEFT

MARK JEVID BARUT VALDEZ,

Respondent.
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Republic of the Philippines)

Ilagan City, Isabela) s.s.

COMPLAINT-AFFIDAVIT

I, FERDINAND ANGOLUAN, of legal age, Filipino and a

resident of Cabaruan, Cauayan City, Isabela after being sworn
to in accordance with law hereby depose and state:

1. That I am the same person who executed this

Affidavit.

2. That I am the authorized representative of the

Complainant TALAVERA HYPERMART, INC, a corporation
duly organized under the laws of the Philippines. (Board
Resolution and Secretary’s Certificate as Annex “A” and “B”,
respectively.)

3. That we are filing these cases of Qualified Theft

against the respondent, of legal age, Filipino and a resident
of Gappal, Cauayan City, Isabela who was employed as the
Store Officer-in-Charge (OIC) of the Talavera Hypermart,
Ilagan City, Isabela. The individual acts (counts) complained
of constituting Qualified Theft were committed as follows:

a. The respondent served as the OIC of the Talavera

Hypermart in Ilagan City, Isabela. As part of his
responsibility, he was reposed with trust and
confidence by the management to protect and
manage the store. He had to see to it that goods are
safekept and personnel perform their work as it
was the Holidays Season. In short, he was the voice

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 of the corporation and management in the store.
(Certificate of Employment as Annex “C”.)

b. On 15 October 2021, the respondent took without

prior consent from the management one (1) Cleene
Kiddie Toothbursh (P36.40) and Apollo Petroleum
Jelly 25g (P39.30) worth P75.70. (Security Guard’s
(SG) Logbook Excerpt as Annex “D”)

c. On 20 October 2021, he took 1 Great Taste 50g BP

Granules (P37.10), 1 Kami Tissue 2P 300 Sheets
4’S (P31.65), 1 Brown Sugar Repack 1/2Kg
(P22.20), 1 Angel Coffee Creamer 200g (P33.45) and
1 Kojie San Dream White Soap 2/135G (P122.30)
with Total Value of P246.70. (Security Guard’s (SG)
Logbook Excerpt as Annex “E”)

d. On 4 November 2021, the respondent took 1 Pink

Yummy Orange (P25.90) and 1 Nail Polish Remover
(P23.45) that costed P49.35. (Security Guard’s (SG)
Logbook Excerpt as Annex “F”)

e. On 14 November 2021, he took 1 Ginebra Franco

4x4 700ml worth P99.50. (Security Guard’s (SG)
Logbook Excerpt as Annex “G”)

f. On 20 November 2021, the respondent took 1 UFC

Banana Catsup 320g Pouch (P20.50) and 1
Magnolia Chicken Spread 220ml SUP (P88.90) with
a total value of P109.40. (Security Guard’s (SG)
Logbook Excerpt as Annex “H”)

g. On 23 November 2021, 1 Bear Brand

W/Iron+Zinc+Vit.C 1.2Kg worth P385.00. (Security
Guard’s (SG) Logbook Excerpt as Annex “I”)

h. Instead of keeping up with the trust and confidence

reposed upon him, on 9 December 2021 at 7:00
o’clock in the evening he increased the number of
items he had been taking:

Unit Description Price

1 THM Gold Rice 10kg P427.00
1 Bearbrand 700g P235.00
1 Del Monte Pineapple Juice P146.00
2 CDO Luncheon Meat 165g P68.30
3 Salinas Green Sardines 155g P56.25

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 Unit Description Price
3 Lucky 7 Karne Norte 150g P57.75
2 Fresca Tuna Caldereta P44.50
1 Fresca Tuna Afritada P22.25
1 Mekeni Pork Tocino 220g P79.75
4 Lucky Me Pancit Canton Kalamansi 80g P48.60
1 PF Hotdog SJ Classic 1Kg P163.85
P1,429.50
(Security Guard’s (SG) Logbook Excerpt as Annex “J”)

4. That the total amount of all the goods he unlawfully

took is at Php2,395.30 (Incident Report by Security Supervisor
as Annex “K”)

5. That the respondent was not given prior authority by

the management to get items from the store even if he was the
OIC during that time.

6. That the respondent unlawfully took with intent to

gain and abuse of confidence the aforesaid personal properties
of the Complainant without its consent.

7. That I attest the truth of the matters herein contained

based on my own free will and volition.

In witness whereof, I have hereunto affixed my signature

this 8thday of February, 2022 at Ilagan City, Isabela.

FERDINAND ANGOLUAN
Affiant
ID (SSS) No. 010998939-4

Subscribed and sworn to before me this _____ day of

____________________ 2022 at Ilagan City, Isabela after
personally examining the Affiant that he understood and
personally executed this Affidavit.