REPUBLIC OF THE PHILIPPINES )

CITY OF BAGUIO ) S.S.

X-----------------------------------------------X

COMPLAINT-AFFIDAVIT
ILLEGAL RECRUITMENT

I, Juan Dela Cruz, Filipino, of legal age, single and presently residing at Lower
Pinget, Baguio City, Philippines, after having been sworned in accordance with law do
hereby depose and say:

1. That I vehemently DENY flatly and categorically all the malicious, baseless,
malevolent, and trump up charges being thrown against me, that I respondent did not in
one way or another as a way of practice involve myself and my prestigious name in the
business of committing illegal recruitment and Estafa whether as an agent or general
manager;

2. That I, respondent is a bonafide businessman engaged in the business of event

planning with business name Party Pop located at 4 th Floor Annex Bldg. Porta Vaga Mall
Session Road, Baguio City.

3. That on March 17, 2015, I met Isabel Valdez together with Lourdes Campos and
Pedro Delos Santos at my place of business located at 4 th Floor Annex Bldg. Porta Vaga
Mall Session Road, Baguio City.

4. That said Isabel Valdez and companions passed by to inquire regarding my event
planning services, that while in my place of business, I overheard them conversing about
wanting to leave for abroad and their need for an agency to help them with their papers.

5. That I interfered and told them about the Integrated Manpower Agency located
across the street at 5F PhilAm Bldg., Upper Session Road, Baguio City.

6. That on March 19, 2015, they returned to confirm their intention to avail my
services for party package A worth One Hundred Thousand Pesos (Php 100,000.00) and
paid the corresponding amount in check numbered 123

7. That the check was issued in the name of Juan Dela Cruz/Party Pop by Isabel
Valdez as full payment for my services

8. That as evidence of the amount received in check, I issued a receipt numbered

1200111 but subsequently gave two more receipts as per request of Lourdes Campos and
Pedro Delos Santos
 9. That the additional receipt issued as proof of their contribution of the above-
mentioned amount however it was issued in blank bearing only my name

10. That the said receipt was filled up by them and made to appear to have been
issued by Integrated Manpower Agency located at T9 3rd floor, Centermall Bldg.,

11. That the said agency located at T9 3 rd flr, Centermall Bldg., was declared to be as
an unlicensed recruitment agency by the certification of the Department of Labor and
Employment attached as Annex D and E in the complaint,

12. That there exist two Integreted Manpower Agency, one located at T9 3 rd floor,
Centermall Bldg., Baguio City which is unlicensed and one located at 5F PhilAm Bldg.,
Upper Session Road, Baguio City which is a licensed recruitment agency as certified by
Annex.

13. That I am in no way related to both agencies as an agent nor as a general manager

14. That I am voluntarily executing this affidavit to attest to the truthfulness of the
foregoing facts and to support the outright dismissal of the complaint filed against me.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 26 th day of February

2016 at Baguio City, Philippines.

JUAN DELA CRUZ

Affiant

SUBSCRIBED AND SWORN TO before me this 26th day of February 2016 in the City
of Baguio, Philippines and I further certify that I have personally examined the affiant
and I convinced and satisfied that he voluntarily executed the foregoing Counter Affidavit
and understood all the contents hereof and that they are true and correct as to his own
personal knowledge.

ATTY. MAE ANN Y. BADUA

Notary Public
Notarial Commission No.331-2018
Roll No. 071015
PTR No.7313108, 1/3/18
Doc. No. 1 IBP No. 785625, 1/2/18
Page No. 2 BADUA-AGUILAR & Associates
Book No. 3 Alviar Tower Building
Series of 2016. Baguio City, Philippines