REPUBLIC OF THE PHILIPPINES) CITY OF MANILA ) S.S.

COMPLAINT AFFIDAVIT I, SOON CHOON KIM of legal age, Korean National, married, a resident of 3 D Ligaya Street, Isadora Hills Subdivision, Barangay Holy Spirit, Quezon City, after having been duly sworn in accordance with law, depose and state that: 1. I am the owner of Jeon Won Family KTV located at Brgy. Holy Spirit, Quezon City, as evidenced by the ___________ dated ____ April, 2009, entered into between me and Mr. KIM TAE CHUL, residing at No. _____, Don Antonio Street, Commonwealth Avenue, Quezon City, in the amount of FIFTY MILLION KOREAN WON or its equivalent in Phlippine Peso: ONE MILLION NINE HUNDRED THOUSAND PESOS (PHP 1,900,000.00) hereto attached as ANNEX “A”; Since May of 2009, I have exercised all the rights and duties of an owner with respect to the said Jeon Won Family KTV. Further, rental fees, electricity, water line and other charges have been regularly charged to and paid by me as owner of said establishment, as evidence by the __________________, hereto attached as ANNEX “B”, “B-1”, “B-2” and “B-2”; The Jeon Won Family KTV has been in operation since ____ May, 2009, under my own management. As a matter of fact, I hired the services of the Caratas Guardians Security Agency to provide security for my business establishment, the Jeon Won Family KTV as evidence by the Service Contract hereto attached as ANNEX “C”; 4. On or about _____________, 20___, I requested Mr. KIM TAE CHUL to make the necessary completion, improvements, and repairs of the facilities and equipment of the Jeon Won Family KTV. The said request is made on the basis of our agreement that the said KTV is fully furnished with all the equipment and furniture in

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KIM TAE CHUL to make the necessary improvement and/or repairs for the establishment as it will not be profitable to operate the said KTV in such a dilapidated state. 2009. 2010. ) S. KIM TAE CHUL. on or about ___________. and repairs of the facilities and equipment of the Jeon Won Family KTV. LUMBRE AFFIDAVIT: REPUBLIC OF THE PHILIPPINES) CITY OF MANILA AFFIDAVIT I. 8. attempted to forcibly open and actually forced open the main door entrance of the KTV on said dates respectively. Andujar Jr. I decided to temporarily ceased the operation of said establishment in order to get the attention of Mr. CLARITO A. The said request is evidence by the First Demand Letter dated _____ hereto attached as ANNEX “D”. 5. reported to me about an incident where Mr. LUMBRE. Further. Again. On 04 and 05 of January. I opted to make a second request demanding for the necessary completion. TWINKIE KIM. security guards Mr. Mr. Kim Tae Chul. and Ms. Said request is evidence by the Second Demand Letter dated 06 January 2009. Thus. hereto attached as ANNEX “E”. of legal age. Affidavits of the foregoing are heretofore quoted as follows: CLARITO A.S. improvements. Filipino. without having obtained any permission from me. KIM.their unspoiled state. KIM TAE CHUL. . 7. Lumbre. As my request was not heeded by Mr. 6. I ordered the security personnel of the Caratas Guardians to temporarily lock the said establishment and instructed them to secure the premises and to open only until notified. Jalil. said request was not honored by Mr. Mrs. and Mr.

While performing our regular duty.. Twinkie Kim who was agitative and hostile. Mr.m. told me that they are still the owners of the Jeon Won Family KTV as Mrs. Cruz. 3. 17 Muelle del Banco. has not paid the remaining balance of the agreed selling price of said establishment. Nacimal St. depose and state that: 1. Thus. Mr. with duty schedule between 12:00 pm to 09:00 pm. Kim and his companions were bringing duplicate keys to door entrance. Soon Choon Kim (Caratas Client).married. City of Manila. at around 04:32 p. after having been duly sworn in accordance with law. Holy Spirit. ordered me to allow them to unlock and open said establishment without authority and prior permission from Mrs. 2. I am a security guard of the Caratas Guardians Security Agency Corporation. Kim and Ms. Soon Choon Kim (Caratas Client). 6. Twinkie Kim arrived at the Jeon Won Family KTV. 5. Kim and his companions who were all antagonistic and aggressive.. . accompanied by Mrs. 4. Ms. Mr Kim. Quezon City. they were insistent in compelling me to give way and consent to their entrance into the establishment. with address at No. On or about January 4.. 2010 I was deployed on duty at Jeon Won Family KTV located at Brgy. presented to me some papers purportedly representing their ownership of Jeon Won Family KTV. Sta.

Grace Adavan’s opinion and Mr.. Grace Adavan. Mr. Soon Choon Kim (Caratas Client) together with Mr. I still refused to heed Ms. Soon Choon Kim (Caratas Client) as the latter was not around when they came to her residence. Kim and his companions to execute their plan as I. locked. together with three (3) other barangay personnel.m. However. 9. Upon their return to the establishment. Ms. for the purpose of settling the dispute. Ms. . Kim and his companions were unsuccessful in communicating with Mrs. Ms. 10. 8. lead by Ms. Kim and his companions. Kim and his companions for the reason that Mrs. Grace Adavan decided to communicate with Mrs. and sealed. 13. was ordered by my direct superior to hold ground and keep Jeon Won Family KTV closed. arrived at the Jeon Won KTV. Mr. Kim and his companion’s insistence to allow them to open the establishment’s door and allow entrance therein. 11. 12. Kim and his companions have with them a purported proof of ownership. at around 5:26 p. Mr. Thereafter. I refused to let Mr. on the contrary. Soon Choon Kim (Caratas Client) was not able to explain her side and that Mr. Kim and his companions were relentless in trying to force open the Jeon Won Family KTV main entrance but to no avail. Grace Adavan. Grace appeared to have sided with Mr.7. Kim and his companions requested the assistance of barangay officials (BPSO) who.

Kim and his companions returned from the police station 6 together with a certain Ms. Mr.14. I. Dionesio “Dave” Andujar. Andujar. . but as expected. Fidel Jalil. and requested us to present our license for recording purposes. I was communicating with Mr. Mr. arrived at the establishment shortly thereafter. still refused to allow Mr.m. 16. Mr. agitative and antagonistic to me and Mr. During this time. 17. Andujar. I advise Mr. who advised me to wait for him to arrive at Jeon Won KTV in order clear and supervise the matter. 20. 15. Kim and his companions to report the incident as evidence by the __________________ hereto attached as ANNEX ____. and again compelled me to allow them to force open the door entrance of the establishment. At around 9:30 p. The police officials suggested Mr. to the Police Station 6 together with Mr. Ms. an official of the Eagle Force Security Agency. 18. a co-securtiy guard of the Caratas Guardians Security Agency. Twinkie requested the assistance of Police Officials who also arrived at the Jeon Won KTV. Inspection Team Member of the Caratas Guardians Security Agency. Ada. Kim and his companions were insistent. via telephone conversation and text messaging. Kim that we will not leave the premises until they leave as we have a direct order from our superiors to secure the same. 19. together with Mr. Kim and his companions to open and enter the establishment.

Jalil. Kim. arrived at Jeon Won Family KTV. I left at or about 11:00 pm. Mr. Shortly thereafter. Twinkie Kim and Ms. Bayking. 29. 2010. and he told me that Mr. I reported the same to my direct superior as soon I have loaded my prepaid sim card. Kim and to leave his the companions decided establishment as they were unsuccessful in trying to compel us to allow them to force open the doors of Jeon Won Family KTV. 25. Bayking of the Eagle Force Security Agency. Security guard Mr. Mr. At or about 11:00 a. At or about the same time the glass door entrance of Jeon Won Family KTV was still close and locked. On or about 10:00 pm. Ms. I saw the said establishment’s aluminum door already rolled-open. when I arrived on my post to perform my regular duty as security guard at Jeon Won Family KTV. 28. Kim opened the same and. 27. 26. through text messaging. of the following day. .. At or about 09:00 a. Edwin Salvador. “who opened the aluminum door?”. already assumed his duty as security guard on Jeon Won Family KTV. 23. have Mr.m. I asked Mr. 21. Ada of the Eagle force Security. of the same day. 24. After having secured Jeon Won Family KTV. 22. January 5. whom Mr.m. requested me not to divulge that he gave said information.

and signed my logbook in order to exonerate me from any liability to my direct superiors and client. Grace Adavan did not allow the former to do so and signed the said log book for Mr. Twinkie Kim hired to open the glass door entrance by means of a crow bar. Twinkie Kim called for Ms. Edwin Salvador to sign our log book as he was the one to perform the opening of the glass door using the crow bar.Kim and Ms. 36. Before attempting again to open the glass door. 35. as I might lose my job as a security guard. Ms. Kim also tried to open the . which I also signed. Grace Adavan that I can not allow the opening of the establishment’s door entrance until after we are given the go signal from our superiors. Albeit my refusal. 32. 31. Grace Adavan told me that I will not have any liability whatsoever. 30. I still tried to stop Mr. Edwin Salvador’s stead. for the purpose witnessing the act of opening the glass doors. Mrs. also arrived at Jeon Won KTV. The Security guards of the Eagle Force Security Agency also requested me to sign their own logbook for the purpose of witnessing the act of opening the glass door. Edwin Salvador to open the said door and the other aluminum door located at the left side which was still unlocked and closed. I also ask Mr. however. Ms. 34. I informed Ms. 33. At that time. Grace Adavan (BPSO Team Leader). Ms.

Edwin Salvador. 38. took photos of the same and removed some of trash of the KTV. Twinkie Kim and notwithstanding my opposition thereto. LUMBRE Affiant . 2010 hereto attached as ANNEX ____. Mr. Kim entered the premises and allowed me to enter also the same to witness that they have taken over the establishment and that they took possession of all the properties therein and placed the same under their control. IN WITNESS WHEREOF. Mr. I have hereunto set my hand this _____ day of January 2010 at _________________________. Mr. (SGD. Kim and Mrs. 39. Kim and Ms. executed the opening of the glass door using the crow bar until he was able to successfully open the same. Andujar. That I am executing this affidavit to attest to the truth of the foregoing and for the purpose of filing appropriate charges in court. I reported the incident to the police as evidence by the Police Blotter dated January 5. Thereafter. Upon advise by Mr. Kim and his companions cleaned the KTV. As soon as the doors were opened.) CLARITO A.glass door using other duplicate keys as it might not be necessary to use a crow bar but she failed to open the same using said duplicate keys. 37. who. 40. upon orders of Mr.

As soon as I was informed thereof. married. AFFIDAVIT: REPUBLIC OF THE PHILIPPINES) CITY OF MANILA AFFIDAVIT I. Pilot Drive. Barangay officials and or personnel on the other hand.. Twinkie Kim. Metro Manila. Mrs. of legal age. Mr. On or about January 4. Ms. 2010. Twinkie Kim. DIONESIO ANDUJAR Jr. 4. and Ms. Kim. depose and state that: 1. detailed at the Jeon Won Family KTV. other security personnel from the Eagle Force Security Agency. Ms. Quezon City. 3. Lumbre. Filipino. Lumbre and Mr. informed me via telephone conversation that Mr. Barangay Commonwealth. Unit 10.DIONESIO ANDUJAR Jr. I immediately went to the Jeon Won Family KTV to conduct the necessary inspection and to shed some light on the matter. Mrs. Kim. Twinkie ) S. When I arrived at the place of said establishment. . Kim. after having been duly sworn in accordance with law. while I was at the Caratas office. Jalil on one hand. and Mr. Mr. I saw our two (2) security guards. are trying to force open the doors of said establishment which were then locked as per order of the superior officers of the Caratas Guardians Security Agency. with address at Block 31. Kim. I am an employee of the Caratas Guardians Security Agency Corporation. 2. one of the security guards of Caratas.S.

”. Kim and his companions will forcibly open the door entrance of the Jeon Won KTV and will disregard our duties as security guards of the establishment.Kim approached me and said in an antagonistic manner that “you do not have any right whatsoever with respect to the Jeon Won Family KTV for you are not holding any document representing ownership of the said establishment. At the Police Station 6. Kim warned that if Mrs. we could be held liable to our superiors and more so to our client. I told Mrs. Thereafter. Mrs. Mrs. Kim (Caratas Client) will not come to the police station to explain her side. issued to us by our superiors. Mrs. Twinkie Kim. and hopefully to clear up some things. a male companion. Kim (Caratas Client). Kim. Kim that the Caratas Security Agency may file Trespassing Charges Against them if they will insist and forcibly open the doors of the . Kim. Police officers from the Police Station 6 arrived at the Jeon Won KTV and advised us (Mr. Mr. I said that if we will accede to their plan to forcibly open the doors of said establishment. 5. and myself) to go to the police station 6 to report the incident as evidence by the ____________________ hereto attached as ANNEX ____. 6. I responded by saying that we are merely performing our job as security guards according to the instructions of our officials in the security agency and that we are merely relying on the Duty Detail Order (DDO) as evidence by the ______________________ hereto attached as ANNEX _____. Ms. Further. 7. 8. And that we are the rightful owner thereof evidenced by the documents we are now holding.

I was informed that the aluminum doors of the Jeon Won KTV have already been rolled open and that the security guards of the Eagle Force Security Agency have already assumed their post thereat. 11.m. Kim and some of his companions inside the premises thereof. trash. I made the necessary inspection of the premises. 13. I returned back to the Jeon Won KTV and upon arrival thereat I ordered security guards Mr. and Mrs. and with Ms. Kim and his companions. I arrived at the Jeon Won KTV only at around 04:00 p. Kim’s intention to go to court and thereafter I left the police station as soon as all necessary matters have been tackled by me and Mr. Jalil. and other materials inside and placing the same outside the establishment. took photos thereof (hereto attached as ANNEX . 9. Lumbre and Mr. Ada of the Eagle Force Security Agency. 14. Because I had to perform some work at the office. Kim adversely responded to me by saying “if that is what you want then let us settle this matter in court. I saw the establishment and all of the properties therein already taken over by and in the possession of Mr. 10. Kim and their companions. Mr. cleaning the same and removing dirt. Mrs. On the following day. to secure said establishment and instructed them to go home only after said establishment is clear from any trespassers.establishment.. 2010. 12.”. with the establishment doors opened. January 5. I acknowledged Mrs.

____________________ after having been duly sworn in accordance with law. married. (SGD. to inform of what transpired. FIDEL JALIL. with address at _______________________________. That I am executing this affidavit to attest to the truth of the foregoing and for the purpose of filing appropriate charges in court. Espina . I sent a text message to our lawyer. ) S. I am a security guard of the Caratas Guardians Security Agency Corporation.S. . Atty.) DIONESIO ANDUJAR Jr. went to the barangay hall to report the incident as evidence by the _____________ hereto attached as ANNEX ____. and the latter advised us to also report the same to the police for purposes of police blotter (hereto attached as ANNEX ___). 15. Metro Manila. I have hereunto set my hand this _____ day of January. depose and state that: 1.____). 2010 in Quezon City. of legal age. Affiant FIDEL JALIL AFFIDAVIT: REPUBLIC OF THE PHILIPPINES) CITY OF MANILA AFFIDAVIT I. Filipino. IN WITNESS WHEREOF.

has not paid the remaining balance of the agreed selling price of said establishment. ordered me and Mr. Mr Kim. While performing our regular duty. Lumbre that they are still the owners of the Jeon Won Family KTV as Mrs. Kim and his companions to execute their plan as we were ordered by our direct superior to hold ground and keep . with duty schedule between 12:00 pm to 09:00 pm. 3. Holy Spirit. 5. Thus. together with Clarito A. Kim and his companions were bringing duplicate keys to the door entrance. also a security guard of the Caratas Security Agency. Mr. Kim and his companions who were all antagonistic and aggressive.2. at around 04:32 p.m. Lumbre. Clarito A. Ms. they were insistent in compelling us to give way and consent to their entrance into the establishment.. On or about January 4. presented to me some papers purportedly representing their ownership of Jeon Won Family KTV.. 6. were deployed on duty at Jeon Won Family KTV located at Brgy. Soon Choon Kim (Caratas Client). We refused to let Mr. Lumbre to allow them to unlock and open said establishment without authority and prior permission from Mrs. 2010 I. 4. Twinkie Kim arrived at the Jeon Won Family KTV. 7. Kim and Ms. Twinkie Kim who was agitative and hostile. Mr. Soon Choon Kim (Caratas Client). told Mr. accompanied by Mrs. Quezon City.

Thereafter. Kim and his companions have with them a purported proof of ownership. 13. Grace Adavan decided to communicate with Mrs. 12. Mr. Kim and his companions. Ms. Upon their return to the establishment. together with three (3) other barangay personnel. 9. Grace Adavan. Ms. . lead by Ms. Mr. Grace appeared to have sided with Mr. Soon Choon Kim (Caratas Client) together with Mr. at around 5:26 p. 8. and sealed. Kim and his companions requested the assistance of barangay officials (BPSO) who.. locked. 10. However. Kim and his companions were relentless in trying to force open the Jeon Won Family KTV main entrance but to no avail. Ms. we still refused to heed Ms. Mr.m. Soon Choon Kim (Caratas Client) as the latter was not around when they came to her residence. Kim and his companion’s insistence to allow them to open the establishment’s door and allow entrance therein. Grace Adavan’s opinion and Mr. Kim and his companions for the reason that Mrs. arrived at the Jeon Won KTV. 11. for the purpose of settling the dispute.Jeon Won Family KTV closed. Soon Choon Kim (Caratas Client) was not able to explain her side and that Mr. Kim and his companions were unsuccessful in communicating with Mrs. Grace Adavan.

Mr. arrived at the establishment shortly thereafter. Lumbre. Clarito A. Kim and his companions to report the incident the Police Station 6 together with Mr. 16. Mr. 15. Clarito A. and requested us to present our license for recording purposes. I. During this time. Ada. 19. Kim and his companions to open and enter the establishment. 20. Kim and his companions returned from the police station 6 together with a certain Ms. together with Mr. who advised us to wait for him to arrive at Jeon Won KTV in order clear and supervise the matter. Andujar. Mr. Ms. Lumbre advise Mr. but as expected. and again compelled us to allow them to force open the door entrance of the establishment. Twinkie requested the assistance of Police Officials who also arrived at the Jeon Won KTV.m. Lumbre was communicating with Mr. 17. Kim that we will not leave the premises until they leave as we have a direct order from our superiors to secure the same. agitative . via telephone conversation and text messaging. The police officials suggested Mr. Dionesio “Dave” Andujar. Mr. Kim and his companions were insistent. 18. Inspection Team Member of the Caratas Guardians Security Agency. Mr. At around 9:30 p. Andujar. an official of the Eagle Force Security Agency. Clarito A.14. refused to allow Mr.

KIM. we left at or about 11:00 pm. 21. at Quezon City. Metro Manila. IN WITNESS WHEREOF. SOON CHOON KIM Affiant SUBSCRIBED AND SWORN to before me. this ____ day of February. KIM TAE CHUL. I am filing a criminal complaint for Grave Coercion and/or Robbery punishable under the Revised Penal Code of the Philippines against Mr. Mr. TWINKIE KIM. After having secured Jeon Won Family KTV. Kim and his companions have decided to leave the establishment as they were unsuccessful in trying to compel us to allow them to force open the doors of Jeon Won Family KTV.. . IN WITNESS WHEREOF. That I am executing this affidavit to attest to the truth of the foregoing and for the purpose of filing the aforementioned criminal case(s) Mr. As a consequence thereof. 2010 at _________________________.) FIDEL JALIL Affiant 9. 22. 2010. Mrs. and Ms. I have hereunto set my hand this _____ day of February 2010 at Quezon City. I have hereunto set my hand this _____ day of January. . On or about 10:00 pm. (SGD. That I am executing this affidavit to attest to the truth of the foregoing and for the purpose of filing appropriate charges in court.and antagonistic to us.

affidavit._______________________________ Assistant City Prosecutor CERTIFICATION The undersigned Prosecutor Certifies that he personally examined the affiant and that he is satisfied that he voluntarily executed and understood his complaint. ______________________________ Assistant City Prosecutor .

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