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]Republic of the Philippines]

City of Cebu . . . . . . . . . . . . ] S.s.

AFFIDAVIT OF COMPLAINT
I, HAROLD S. CUERDA, of legal age, and a resident of with office address
located at Olivares Plaza, NAIA Ave., San Dionisio, Parañaque City , after having
been duly sworn to in accordance with law, do hereby depose and say:

1. That I am the Chief Operating Office of Explorer Freight Corporation,


a corporation duly organized and existing under the laws of the Republic of the
Philippines with principal office located at Olivares Plaza, NAIA Ave., San
Dionisio, Parañaque City, as shown by the Certificate of Registration No. 182139,
machine copy of which is hereto attached as Annex “A”;

2. That sometime March 2008, I was informed by my Finance Officer Rena


Lirasan that ALLAN SUSON altered the supporting papers of his
LIQUIDATION OF EXPENSES FORM;

3. That I immediately instructed Rena Lirasan to forward to me hard


copies of the transaction so that I can evaluate the same;

4. That the particulars of ALLAN SUSON’s acts are best described in Rena
Lirasan’s Affidavit hereto attached as Annex “B” and made as an integral part
hereof;

5. That lately ALLAN SUSON committed other serious misconduct


prejudicial to EXPLORER FRIEGHT CORPORATION for which reason the said
Corporation, through its Board of Directors, has directed to file the instant case
against ALLAN SUSON for the crime of ESTAFA;

6. That Machine copy of the Secretaries Certificate authoring me to


institute the instant complaint is hereto attached as Annex “A”;

7. That I execute this affidavit to attest to the truth of the foregoing and for
whatever purpose it may serve and to support the instant complaint against
ALLAN SUSON for the crime of estafa .

IN WITNESS WHEREOF, we have hereunto affixed our signature this ___


day of June, 2012 in the City of Cebu, Philippines.

HAROLD S. CUERDA
Affiant
SUBSCRIBED AND SWORN to before me this ___ Day of June, 2012
in the City of Cebu, Philippines. The undersigned notary public has explained to
the affiant each and every paragraph of the foregoing affidavit and he
acknowledged to me that he understood what I have explained to him.
Doc. No. ____
Page No. ____
Book No. ___
Series of 2012

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