Republic of the Philippines

12th Judicial Region

Regional Trial Court, Branch - ___
Iligan City

Joseph Raymond B. Purganan

Complainant

-versus- Criminal Case No.____

For: Qualified Theft

Jennifer Jimenez,
Monica Reyes
Respondents

COMPLAINT-AFFIDAVIT

I, Joseph Raymond B. Purganan, single, of legal age, a Filipino and a

resident of Purok 4, Tibanga, Iligan City aftert having been duly sworn in
accordance with law do hereby depose and state that:

1. I am the plaintiff in this matter and I have personal knowledge of the

matters herein referred to.

2. I am the sole owner of Lola G Café, a coffee shop located at Door 8,

Chelina Arcade, Tibanga, Iligan City.

3. That on August 27, 2022, Jennifer Jimenez and Monica Reyes were hired
in my café as a Barista and a waitress respectively. Both are referred to
herein as the respondents.

4. That on March 15, 2023, I received a text from PDLT that my outstanding
bill for the month of February is Php12, 500.

5. This left me aghast and wondered why my PLDT soared that high since my
regular monthly bill is only Php1,500.

6. I asked my staff in the café Jennifer Jimenez and Monica Reyes, the
respondents herein, if they had received a PLDT Billing letter which we
usually receive every first week of the month but both denied having
received such.

7. I then went looking for files and envelopes in the cashier table and there I
found at the very bottom the already opened PLDT billing letter for the
month of February which had stated that my outstanding bill was indeed
Php12, 500.
8. That upon checking at the last page of the billing letter I discovered a long
list of mobile phone numbers that were called using my PLDT landline that
 caused the bill to balloon. A copy of this billing letter is herein attached to
as Annex “A”.

9. That upon asking Jennifer Jimenez and Monica Reyes, they denied having
the ones responsible for calling such mobile numbers.

10. I then asked both of them to dial few of the numbers listed and to my
surprise, the dialed numbers were actually registered in their mobile
phone’s phonebook.

11. Two mobile numbers, 09263456780 and 09223567892 were two of the
most frequently dialed numbers with a minimum duration of 30 minutes
were dialed and called for three to four times daily. (Kindly refer to Annex
“A”)

12. That the 09263456780 was registered as “Bebe ko” in Jennifer Jimenez’
mobile device and the 09223567892 was registered as “MyLabs” in
Monica Reyes’ mobile device. Photos were taken and are referred
hereinafter as Annex “B” and “C”.

13. That on March 16, 2023 I am forced to pay the Php12,500 PLDT bill in
order to avoid disconnection since my PLDT internet connection is a vital
part in my business.

14. Qualified Theft is a crime against property, and it is a criminal charge

punishable under the Revised Penal Code. The very essence of this offense
is the taking, without the consent and with intent to gain, of the personal
property of another. Indispensably also, the taking must be with grave
abuse of confidence and without any violence against the persons or any
force upon things. Thus, it is an unlawful taking in the eyes of the law.

15. I am executing this complaint-affidavit to attest to the truth and veracity of

the foregoing statements, to file a formal complaint of QUALIFIED
THEFT against Jennifer Jimenez and Monica Reyes and for any legal
purposes it may serve.

Joseph Raymond B. Purganan

Affiant

SUBSCRIBED AND SWORN to before me this 4th of April 2023 by Joseph

Raymond B. Purganan who exhibited to me his Community Tax Certificate No.
234567 issued at Tibanga, Iligan City on 3rd of April 2023.

Atty Nestle S. Agopitac

Notary Public
PTR No. - 5114349 / Jan.4, 2022
IBP No. - 192282/ Jan. 2, 2022
 ROLL No.61982
MCLE Cert. of Compliance No. VI-00000276
Valid until April 4, 2022
Notarial Certificate Serial Number 033-07-2015
Poblacion, Tubod, Lanao del Norte
Doc. No. __
Page No. __
Book No. __
Series of 2022.