Republic of the Philippines) City of Davao ) S.S. x--------------------x
COMPLAINT
The complainant, Carlo Cruz, accuses Ana Lu and Elizabeth Lu, of QUALIFIED THEFT, and respectfully avers that: 1. Carlo Cruz is the lawful owner of a Shopping Mall, operating under the name of “CC Mall” located at Bajada, Davao City; 2. Ana Lu was hired by the complainant in January 2018 as Operations Supervisor, being experienced on such function with commendable academic records. She was even indorsed for hiring by Carlo Cruz’s mother; 3. Inherent to his position, Ana Lu has access to the various department and store rooms where articles, materials, and supplies of the said mall were stored. Thus, her designation was impressed with the owner’s confidence; 4. On 1st day of March, 2019, Ana Lu, did then and there willfully and feloniously, with grave abuse of confidence, with intent to gain and without the consent of the owner thereof, take, steal, and carry away from the said mall, P100,000.00 cash collections for the day and 2 units Lenovo Laptops valued at P40,000.00 each, to the damage and prejudice of CC Mall and its owner Carlo Cruz; 5. Elizabeth Lu was the cousin of Ana Lu, currently employed at the Landbank of the Philippines, Bajada Branch, Davao City; 6. Without having participated in said crime either as principal or accomplice, Elizabeth Lu, then and there unlawfully take part subsequent to its commission by profiting herself and assisting accused Ana Lu to profit by the effect of the crime, by then and there buying the said laptops from Ana Lu, knowing that they had been stolen.
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Davao City, this 2nd day of March, 2019.
CARLO CRUZ
Complainant/Offended Party
WITNESSES: ________________________ ________________________
SUBSCRIBED AND SWORN TO before me this 2nd day of March 2019 in Davao City, affiant exhibited to me his SSS Identification Card No. 1234 issued on April 5, 2017 in Davao City. WITNESS MY HAND AND SEAL.
NOTARY PUBLIC
TRRU LAW OFFICE Counsel for Defendant Dr. 2 Esperanza Bldg., 198 Tulip Drive, Ecoland, Matina, Davao City Tel. +6382 2412941. Mob. +639322984878; Email. Email.
[email protected]
By:
ELLAN GET N. TINGSON Roll of Attorneys 2017300373 MCLE Compliance III-0000001 PTR OR No. 123456B; 06/05/2018; Davao City IBP OR No. 002076; 05/19/2021; Davao City
EDITHA L. ROXAS Roll of Attorneys 2018400062 MCLE Compliance V-001221; 5/4/2018; Davao City PTR OR No. 5392795; 7/8/2018; Davao City IBP OR No. 00333
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FAITH IMEE D. ROBLE Roll of Attorneys 2018400057 MCLE Compliance V-0021173; 5/4/2018 PTR OR No. 123465; 1/4/2018; Davao City IBP OR No. 00233
HANNA-TUNISIA F. USMAN Roll of Attorneys 2018400036 MCLE Compliance V-0021116; 5/4/2018 PTR OR No. 0000000A; 1/1/2018; Davao City IBP OR No. 000001
Republic of the Philippines Philippines)) Davao City )S.S. AFFIDAVIT OF SERVICE
I, Ne Mo, as Legal Assistant of the TRRU Law Office, with address at Dr. 2 Esperanza Bldg., 198 Tulip Drive, Ecoland, Matina, Davao City, under oath depose and say: On 18thday of February 2019, I filed with the Honorable Court and served a copy of the following pleading/paper: ANSWER TO THE COMPLAINT WITH COUNTERCLAIM
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On the other party in Civil Case No. R-DVO-29-2019-CV , for Recovery of parcel of land and building (Accion Publiciana) on expired lease, Spange Bab, plaintiff , vs. Squid Ward, respondents , , pursuant pursuant to Rule Rule 13 of the the Rules of Court: Court: By personal Service: SPANGE BAB
Plaintiff Block 32 Lot 31 Clarity Street Pag Ibig Homes, Buhangin Davao City, Davao Occidental, Philippines Received Receive d by: ___________________ Date: __ February 2019
JEDAIDAH V. LIBRES
Affiant SUBSCRIBED AND SWORN to before me this 18th day of February 2019 in Davao City, Philippines, affiant exhibiting to me her BIR TIN 444-555-661, as competent proof of identity. Doc. No. __; Page No.__; Book No. I; Series of 2019.
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