Metro Manila x- - - - - - - - - - - - - - - - - - - - - -x AFFIDAVIT OF COMPLAINT The UNDERSIGNED Cipriano Mendoza , accuses Angelo Mangilit and two other nurses (stationed nurse of the The Manila East Medical Center (Tata!" The undersigned reposes and a#ers the following antecedent facts , to wit$ -That % , Cipriano Mendoza, am the son of the patient in Manila East Medical Center Tata who was admitted last March &', ()'*" -That the patient+s name was Corazon Mendoza, &, ears of age and was confined and medicated for &-* das in the said hospital" -That upon recommendation of the commissioned doctor in the Emergenc -epartment named -r"Tan ,the patient was referred to the %C. -epartment of the hospital" -That upon referral to the %C. ,%, /eing the son of the patient, cancelled the referral made / -r"Tan since % and m sister (Conchita Mendoza! ma not see regularl the condition of the patient " -That upon the re0uest of transfer from the %C. to a regular room, the famil doctor (who is -r" Ra/anal! of the patient agreed through telephone that the patient ma /e transferred originall from %C. to a regular room" %n addition to this, we also as1ed the permission of the admission office #ia a named 2hela if we can transfer the patient from %C. to a regular room since she was there onl for some minutes" The Admission 3ffice agreed in the affirmati#e" -That % also tal1ed to the doctor in charge in the %C. -epartment for the transfer of the patient and the doctor in charge also agreed with our re0uest of transfer pro#ided % should #erif it with the Admission 3ffice and pro#ided further that % should see1 the appro#al of -r" Ra/anal(the famil doctor!" -that certain nurses were commissioned in the %C. namel4 Angelo Mangilit and the two other colleagues of his ,whom % was not a/le to get the name from the Admitting 3ffice, who too1 care of the patient" -That said stationed nurses+ scope of responsi/ilit was to endorse the patient for transfer from %C. to a regular room " -That % made a follow up to the said nurses not twice /ut man times for the endorsement of the patient /ut to no a#ail" The ali/i of the said nurses was that there were some guidelines to /e followed /efore the patient ma /e transferred from their %C. -epartment to a regular room" 5owe#er, % found out later that the endorsement should /e made onl #er/all / the said nurses" -that in m confusion of who will endorse the patient, % ha#e as1ed the nurses commissioned outside the %C. if the were the one in charge for the endorsement of the patient and informed me that the nurses who were assigned in the %C. were the ones accounta/le for the release and transfer of the patient" -that % was amazed / the fact that Angelo Mangilit and compan, the nurses stationed inside the %C. ,were the nurses responsi/le for the transfer and endorsement" -That while waiting for two and a half hours for the endorsement of the patient from %C. to a regular room, % did another follow up from the said nurses and the told me again that it was not eas for the patient to /e transferred urgentl /ecause there were necessar steps to /e followed" %+#e as1ed the nurses if what was the tpe of endorsement the need to do, so that the patient ma /e transferred urgentl6 The replied that % should wait, so, % decided to wait outside for them" -That in waiting for another &) minutes, % made another follow up in the %C. -epartment, % ha#e told mself that this should not /e happening /ecause the life of the patient was #er important and that the waiting shall not /e restrained for long hours 7ust for the negligence of these nurses commissioned / the %C. -epartment and moreo#er, for the dela in the ser#ices of the patient and patient+s relati#es" -That thenceforth, %+#e finall as1ed Angelo Mangilit and compan wh there was a dela of transfer65e answered that % should wait" % told him that he should ha#e endorsed the patient alread /ecause three hours had alread elapsed and that, as a customer of the hospital and patient as well, we should not /e experiencing this 1ind of treatment / the nurses and the hospital" % deemed that there was a clear neglect of dut on the part of the nurses and moreo#er, on the part of the hospital, too" -That % ha#e as1ed again Mr"Angelo Mangilit , 8h6, he onl replied that the ha#e to finish the process for transfer and some guidelines for endorsement and this was the main reason wh the patient must not /e transferred immediatel from the %C. to a regular room"9o that was their reason wh the patient was not transferred for & hours" % told them that the should transfer the patient #er/all /ecause this was the onl re0uirement mentioned to me / the nurses commissioned outside the %C." -That % ha#e as1ed Mr" Mangilit , what is his name6(/ecause / that moment ,% don+t 1now his name!" 5e replied to me /oastfull and with a high tone of #oice in Tagalog, :A1o si Angelo, /a1it6 (sarcasticall and angr!" % then again as1ed his surname, he answered again in the same actuations :Mangilit, /a1it6, %1aw /a sino 1a /a6(angr and with a high tone of #oice!" -That e#en though the were angr with me and with a high tone of #oice, % did not lose m control and answered then that % was the son of the patient" Afterwards, % as1ed them again if the ha#e a Manager whom % can tal1 to regarding the matter /efore the situation /ecomes out of control" -That after this incident, % went down and as1ed the Admitting 3ffice if % can tal1 to a Manager of the 5ospital or someone % could tal1 to in order to rela m grie#ances or explain the treatment % experienced from the nurses" The Admitting 3ffice called someone o#er the telephone and told me to wait to the lo// "9u/se0uentl after a/out ')-'; minutes, a man approached me and told me that he was the head nurse, his name was Mr" Alex"(the head nurse assigned that night!" -That Mr"Alex as1ed me a/out what happened and % explained the incident to him in the Admitting 3ffice" % was fortunate that % ha#e tal1ed to him to express m complaints" After narrating to him the e#ent that had happened in the fourth floor of the hospital, where the %C. was located, he told me that he will ma1e an incident report regarding the matter and he will also as1ed Mr" Angelo Mangilit a/out the e#ent" .nfortunatel, according to him, Mr" Angelo Mangilit alread went home" % told him if what 1ind of endorsement is needed in order to transfer the patient, he answered that it was onl a #er/al endorsement" 9o, % as1ed him wh the nurses he handled too1 more than & hours to transfer a patient, he replied that he will ha#e to tal1 to the nurses in#ol#ed" % told him that this should not happen /ecause we are the customer , and the hospital exists /ecause there are patients and customers" -That une0ui#ocall, there was no good customer ser#ice / the hospital and that the emploees of the hospital were not doing their 7o/" Conse0uentl, that there was negligence and dela in the endorsement of the patient" -That finall, % made alread a complaint affida#it to the hospital+s customer ser#ice /ut it seems the hospital too1 no action of this matter and that % thin1 that the hospital was onl protecting its /usiness as well as its emploees" -That now, thenceforward, % ha#e come into our office to su/mit this complaint affida#it against the nurses in#ol#ed for their neglect of dut resulting for the dela of the patient+s release and transfer from the %C. to a regular room" -That % also pra into our good office that these nurses /e apprehended ,especiall Angelo Mangilit and compan ,and /e sanctioned for disciplinar measures or ma /e suspension from wor1 irregularl to #indicate the moral sufferings, mental anguish and social humiliation we had experienced in the Manila East Medical Center Tata" -That said nurse must defra the necessar damages we suffered from them for sociall humiliating us inside the hospital" -that notwithstanding the complaint affida#it % presented to the customer ser#ice of the hospital and the formal demand to explain the actions of the a/o#e-mentioned emploees, respondent failed and refused to resol#e the matter" % am therefore executing this Complaint-affida#it to attest to the truth of the foregoing facts and for the purpose of initiating an administrati#e and ci#il action against the respondent for #iolation of their oath for con!uct unbeco"in# of $ nu%se& AFFIANT FURT'ER SA(ET' NAUG'T&
IN )ITNESS )'EREOF % ha#e hereunto affix m signature this <<<da of April <<<, ()'* in <<<<<<<<< Cit, Philippines" CIPRIANO ELESEO MENDO*A Affiant SU+SCRI+ED AND S)ORN to /efore me this << da of April ()'* in <<<<<<<<<Cit, Philippines" % certif that % ha#e personall examined the affiant and that % am satisfied that he personall executed the foregoing C3MP=A%>T-A??%-A@%T and that he full understood the same"
The Crime of Estafa Is A Continuing or Transitory Offense Which May Be Prosecuted at The Place Where Any of The Essential Elements of The Crime Took Place