Republic of the Philippines)

City of ________________)S.S.
x--------------------------------------------x

AFFIDAVIT

I, GRASIELA D. GO, of legal age, Filipino, single, with principal address at c/o
S. Herrera Brothers, Inc. with business address at Door 3, H&C Building, Alvarez St.,
Davao city, after having been sworn to in accordance with law, hereby depose and say
that:

1. I am the Operations Manager/Purchasing Manager of S. Herrera Brothers, Inc.

and its sister company, Wide Reach Mobile Communications, Inc., (collectively
known as “Company” for brevity) located at Door 2, H&C Building, Alvarez St.,
Davao city;

2. The Company is engaged, among others, in the business of retail/wholesale of

cellular phones of different brands and models, including accessories (“units” for
brevity);

3. As the Operations Manager/Purchasing Manager of the Company, included in

my job is to oversee and supervise the over-all operations of the Company,
particularly in the procurement, inventory, safekeepimg and selling the aforesaid
units. I also collaborate with respondent Batoon, an employee of the Company
since 2013 who was designated as CUSTODIAN (inventory-in-charge) of these
units;

4. On 20 January 2020, Celestino Hindap Jr. (“SG Hindap” for brevity) approached
me and reported to me and to Honey Michelle H. So (hereinafter referred to as
“Ms. So”), the owner of the Company, that Ms. Batoon refused to have her
pouch bag checked last Saturday (18 January 2020);

5. Immediately thereafter, we conducted a spot audit of all the units of the

Company, especially those under the care and custody of Ms. Batoon and found
out that there were indeed missing units;

6. During the audit and inventory of the units, we observed that the boxes wherein
the stolen units were stored by 10’s were not missing. Ms. Batoon just made it
appear that these empty boxes still have the units by placing them (empty boxes)
at the rear portion of the stock room;

7. After we made our initial investigation, I was shocked, flabbergasted and

dumbfounded with the quantity of items stolen. We discovered that the
following units were missing: 20 units of Oppo A5s, 10 units of Oppo A5 2020
4gb, 8 units of Vivo S1, 93 units of Vivo Y11, 40 units of Vivo Y15, and 3 units of
Vivo Y91c, or a total of 181 units (equivalent to Php1,288,549.00 Suggested Retail
Price (SRP);

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8. Thereafter, we confronted Ms. Batoon and demanded from her an explanation.
At first, she was dead-silent but a few minutes later, she verbally ADMITTED to
have stolen them. She even volunteered to have her ADMISSION be put in
writing and promised to pay their value in installments;

9. When asked where the units are, Ms. Batoon replied that some of the units were
at her house and some were pawned at various pawnshops, such as CVM
PAWNSHOP AND MONEY CHANGER CORP. and RENALYN M.C.
CELLSHOP AND TRADING, INC.);

10. After knowing all these, we immediately went to Ms. Batoon’s house where we
recovered thirty-three (33) units. Thereafter, we immediately went to Sta. Ana
Police Station of Davao City where we reported the same to the Police for record
purposes;

11. The next day or on 21 January 2020, we went to the Barangay Hall of Brgy. 9-A
Poblacion to report the said incident. There, Ms. Batoon willingly executed
another ADMISSION in front of Hon. Roderico A. Llubit, the Barangay Captain,
that she stole the said items and promised to pay their value;

12. Meanwhile, we endeavored to recover the stolen units from various pawnshops
and we were able to recover another fifteen (15) units;

13. We also demanded from CVM Pawnshop and Renalyn Pawnshop the return of
these stolen items considering that under the circumstances of their transaction
with Ms. Batoon, there were clear indicia that the said units are subject of a
crime, in this case, Qualified Theft;

14. Despite our demand to return these stolen items, CVM Pawnshop and Renalyn
Pawnshop refused to return the same;

15. To summarize the incident, Ms. Batoon, with intent to gain, stole ONE
HUNDRED EIGHTY ONE (181) UNITS of CELLPHONES from the Company
(owner of the 181 units), summary of which is provided below, to wit:

Brand/Model No. of SRP per unit Total SRP

Units

VIVO Y11 100 Php5,999.00 Php599,900.00

VIVO Y15 64GB 40 Php7,999.00 Php319,960.00

VIVO S1 128GB 8 Php12,999.00 Php103,992.00

OPPO A5S 3GB 20 Php6,990.00 Php139,800.00

OPPO A5 2020 4GB 10 Php10,990.00 Php109,900.00

VIVO Y91C 3 Php4,999.00 Php14,997.00

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 181 TOTAL Php1,288,549.00

16. Thereafter, we were able to recover THIRTY-THREE (33) UNITS from Ms.
Batoon’s house and later, another FIFTEEN (15) units from other pawnshops,
leaving ONE HUNDRED THIRTY THREE (133) UNITS still in possession of
CVM Pawnshop and Renalyn Pawnshop. Summary of the 133 units in
possession of both CVM Pawnshop and Renalyn Pawnshop is as follows:

Brand/Model No. of SRP per unit Total SRP

Units

VIVO Y11 60 Php5,999.00 Php359,940.00

VIVO Y15 64GB 38 Php7,999.00 Php303,962.00

VIVO S1 128GB 8 Php12,999.00 Php103,992.00

OPPO A5S 3GB 20 Php6,990.00 Php139,800.00

OPPO A5 2020 4GB 5 Php10,990.00 Php54,950.00

VIVO Y91C 2 Php4,999.00 Php9,998.00

133 TOTAL Php 972,642.00

17. While the following is the summary of the stolen items in possession of
respondent CVM Pawnshop alone:

Brand/Model No. of SRP per unit Total SRP

Units

VIVO Y11 30 Php5,999.00 Php179,970.00

VIVO Y15 64GB 35 Php7,999.00 Php279,965.00

VIVO S1 128GB 8 Php12,999.00 Php103,992.00

OPPO A5S 3GB 1 Php6,990.00 Php6,990.00

74 TOTAL Php570,917.00

18. On the other hand, the following is the summary of stolen items in possession of
Renalyn Pawnshop:

RENALYN M.C. CELLSHOP AND TRADING, INC.

Door #2, Carlson Bldg., Lapu-lapu St.,
Agdao, Davao City
Brand/Model No. of SRP per unit Total SRP
Units

VIVO Y11 1906 30 Php5,999.00 Php179,970.00

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 VIVO Y15 64GB 2 Php7,999.00 Php15,998.00

OPPO A5S 3GB 16 Php6,990.00 Php111,840.00

OPPO A5 2020 4GB 3 Php10,990.00 Php32,970.00

51 SUB-TOTAL Php340,778.00

RENALYN M.C. CELLSHOP AND TRADING, INC.

Door 5 LAT Bldg., Bonifacio St., Brgy. 34-D, Davao City
Brand/Model No. of SRP per unit Total SRP
Units

VIVO Y15 64GB 1 Php7,999.00 Php7,999.00

OPPO A5 2020 4GB 2 Php10,990.00 Php21,980.00

VIVO Y91C 2 Php4,999.00 Php9,998.00

5 SUB-TOTAL Php39,977.00

RENALYN M.C. CELLSHOP AND TRADING, INC.

Door 2 Amparo Bldg., Brgy. 12-B, JP Laurel Ave., Davao City
Brand/Model No. of SRP per unit Total SRP
Units

OPPO A5S 3GB 3 Php6,990.00 Php20,970.00

3 SUB-TOTAL Php20,970.00

OVER-ALL UNITS 59 GRAND Php401,725.00

TOTAL

19. I am executing this Affidavit to attest to the truth of the foregoing and for any
legal purpose it may serve.

IN WITNESS WHEREOF, I have hereunto set my hand this ____ day of

February, 2020 at ___________________________, Philippines.

GRASIELA D. GO
Affiant

SUBSCRIBED AND SWORN to me this _____ day of February, 2020, in Davao City,
affiant exhibiting to me her ___________________________.

Doc No.: _____

Page No.: _____

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Book No.: _____
Series of 2020.