REPUBLIC OF THE PHILIPPINES

OFFICE OF THE CITY PROSECUTOR

CITY OF DAVAO

ANTON SHUGOR
Complainant, I.S. No. 231547

- versus - For: Qualified Theft

Art. 310 Revised Penal Code

MIKA SANTOS
Respondent.

x---------------------------------x

COMPLAINT-AFFIDAVIT

I, ANTON SHUGOR, of legal age, Filipino, an accountant, with

residence at No. 9 Cross Road St. Valley Subd. Davao City, after having been
sworn in accordance with law, hereby states:

1. I am filing a complaint under Article 308 of the Revised Penal Code for
Theft against Ms. MIKA SANTOS, hereinafter referred to as respondent, of
legal age, and with residence at 76 B Brgy. Bucana, Davao City.

2. The respondent was referred to me by my acquaintance at work, Ms.

Rose B. Umali, after I mentioned that I needed the services of a maid and
cook for a duration of six months. The respondent was likewise informed
that I needed household help, and through Ms. Umali, we exchanged phone
numbers and agreed on a day in which the respondent will start with her
duties.

3. On February 15, 2020, the respondent arrived at around 1PM. I oriented

her to her duties and showed her around my house in order to familiarize
her with the area,

4. The following day, she officially started her duties as a part of the
household help. I left home for work at 6am after giving her instructions on
what to do for the day. I arrived home from work at 9:30PM and checked if

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all her tasks were accomplished. Everything was in order and I decided to
retire for the day.

5. We followed the same routine for one week. On March 20, 2020, when
respondent was out on a day off, I was going through my clothes basket,
looking for my Rolex Speedmaster Watch. I was not able to find said item
and decided to ask respondent as to its whereabouts through a text
message. She replied that she had not seen the watch but volunteered to
look for it once she returned. However, I had forgotten to inquire about it
the following day.

6. Two weeks passed after that incident before I noticed that something
was amiss. On March 15, 2020, when respondent was having her customary
day off, I noticed that seven out of the twenty porcelain figurines I owned
were missing. I also could not find several designer shirts that I owned and
my pressure cooker was likewise missing. I also checked my drawers that
day and I discovered that my .45 caliber pistol, laptop and tablet had been
taken as well.

7. I decided to report the incident to the police that same day, but before I
left my house, my neighbor, Ms. Kimberly Reyes, approached me and said
that she kept seeing the respondent talking to a man by the gate and saw
on March 10, 2020, between 10 to 11 AM, that said man was permitted to
enter the house by the respondent and later exited the premises while
carrying the respondent's belongings with the addition of a big brown bag.

8. I reported the incident on that same day and tried to contact the
respondent, but she could not be reached and never showed up for work
thereafter.

9. Her acts are clearly within the purview of the of Article 310 of the
Revised Penal Code, as she had taken personal belongings without consent
and without employing violence, intimidation and threat upon the rightful
owner, with grave abuse of confidence.

PRAYER

Wherefore premises considered, it is respectfully prayed after notice and

hearing that the respondent be:

1. Indicted with the violation of Article 310 of the Revised Penal Code
2. Such other remedies that may arise from the complaint

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 ANTON SHUGOR
Complainant

VILLARIN LAW
Unit 11 & 12,City Triangle Corporate Center,
CM Recto St., Davao City

By:

ATTY. PAULO JOSE S. VILLARIN

Counsel of the Complainant
Roll of Attorneys No. 696969
PTR No. 69669, 4-24-20, Davao City
IBP No. 5559, 4-24-20, Davao City
MCLE Compliance No. VII-0220293; 4-19-19
Valid until April 14, 2022
Ecoland, Davao City

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 VERIFICATION AND CERTIFICATION OF NON-FORUM SHOPPING

Republic of the Philippines)

Davao City) S.S.

I, ANTON SHUGOR, of legal age, Filipino, single, and a resident of Davao

City, Philippines, after being sworn in accordance with law, hereby depose
and certify that:

I have not theretofore commenced any other action or proceeding or

filed any claim involving the same issues or matter in any court, tribunal, or
quasi-judicial agency and to the best of my knowledge, no such action or
proceeding is pending therein; If I should thereafter learn that the same or
similar action or proceeding has been filed or is pending before the
Supreme Court, the Court of Appeals, or any other tribunal or quasi-judicial
agency, I undertake to report such fact within five (5) days therefrom to the
court of agency wherein the original pleading and sworn certification
contemplated herein have been filed.

IN WITNESS WHEREOF, I have hereunto set my hand this March 18, 2020
at Davao City, Philippines.

ANTON SHUGOR
Complainant-Affiant

SUBSCRIBED AND SWORN to before me, this 18th day of March, by

affiant ANTON SHUGOR who exhibited to me his SSS ID NO. 123451231245
issued at Davao City, Philippines on January 20, 2020.

Doc. No. __;

Page No. __;
Book No. __;
Series of 2020.

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 CERTIFICATION

I HEREBY CERTIFY THAT I HAVE PERSONALLY EXAMINED THE AFFIANT

AND I AM SATISFIED THAT SHE VOLUNTARILY EXECUTED AND UNDERSTOOD
HER AFFIDAVIT.

PROSECUTOR JACKY CHAN

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