REPUBLIC OF THE PHILIPPINES )

____________________
) SC.
COMPLAINT AFFIDAVIT
I, _____________, of legal age, Filipino, and with an office address at
_____________________, Philippines, after duly sworn to in accordance with law,
hereby depose and say that:
1. I
am
presently
employed
as
______________________,
(the
Complainant). The Company is a corporation duly organized and
existing under and by virtue of the laws of the Republic of the
Philippines, and engaged in the business of providing __________ and
____________ to the public, with principal place of business at
_______________.
For purposes of this complaint-affidavit, I am duly authorized by the
complainant to initiate this instant complaint-affidavit as evidenced by
a copy of the Secretarys Certificate dated _______is hereto attached,
marked and made integral part hereof as Annex A.
2. Respondent ______________ (Respondent), is of legal age, Filipino, with
postal address at ___________________, and was an employee of the
Company as _________ for _____________ from 1 February 2010 until his
sudden resignation on 14 September 2014.
3. As ___________ for ______________________, the respondent handles day
to day transactions involving airline passenger bookings and/or
request, make and confirms travel reservations and lodgings, sells
itinerary and tour packages, handles group bookings for corporate and
government accounts, VIPs and passenger special request and update
daily sales report of the branch. Respondent is also granted access to
the various log-in system of the Company for purposes of booking and
issuing airline tickets to passengers. The issued airline ticket to the
passengers has been prepaid by the Company to the airline company
issuing the ticket through funds provided by the Company to the airline
which has to be replenished from time to time by the Company. Hence,
upon issuance of the airline ticket, the cost of ticket is automatically
deducted by the airline from the said fund. Therefore, upon issuance of
the airline ticket, the cost of ticket must be immediately collected by
the Company to the respondent in full trust and confidence solely for
official Company transaction.
4. No ticket shall be issued to the passenger by any employee of the
Company, including the respondent, without any official receipt of
payment issued by the Company cashier being shown by the
passenger to the employee of the Company attending the booking and
issuance of ticket for the passenger.
5. Sometime in October 2014, the Companys Accounting Department
conducted reconciliation of sales recorded by the employees on their
Google docs reporting system, as implemented by the Company, as
against the actual sales of the Companys employees based on their
issued tickets.

6. On 19 November 2014, the Accounting Department issued a report

finding unreported/unrecorded and unremitted sales of the Company
amounting to a total Pesos: _________________________________ arising
from transactions made by the respondent, using his Company
provided log-in or access code to book passengers in the Companys
booking system, during his employment with the Company and
covering the period March to August 2014. A copy of the report of the
Companys Accounting Department is hereto attached and made an
integral part hereof as Annex B.
7. Thereafter, the Company verbally demanded from and even sent a
letter dated 21 November 2014 to the respondent at the respondents
last know registered address demanding payment of the
aforementioned unreported/unrecorded and unremitted sales of Pesos:
_______________________. Despite thereof, respondent failed and
continuously fail to pay the same up to present to the damage or
prejudice of the Company. A copy of the Companys demand letter
dated 21 November 2014 is hereto attached and made an integral part
hereof as Annex C.
8. Respondent, by the nature of his position, transacted passenger
booking transactions using the access code provided to the respondent
by the Company in confidence and for official transaction solely
benefitting the Company. However, respondent abused the trust and
confidence reposed upon him by the Company wherein he booked
customers for airline flights without reporting/recording and remitting
the sales to the Company to the prejudice of the latter. Clearly,
respondent used his position to deceitfully gain from the Company.
9. I am executing this affidavit to attest to the truth of the foregoing and
for the purpose of initiating the prosecution of the respondent for
Qualified Theft and/or Estafa under the Revised Penal Code of the
Philippines.
IN WITNESS WHEREOF, I have hereunto set our hands this ____ day
of _______ 2015 in ____________, Philippines.
xxxxxxxxxxxxxxxx
Affiant
SUBSCRIBED AND SWORN TO before me this _______ day of
__________ 2015 in ____________.

Administering Officer

CERTIFICATION
I hereby certify that I have personally examined the affiant and that I
am satisfied that he voluntarily executed and understood his complaintaffidavit.

Administering Officer