ATMOSFERA, RALPH

BELTRAN, MIKHEL
MADRID, GIAN
YRREVERRE, EMMANUEL
LEGAL WRITING – G05

REPUBLIC OF THE PHILIPPINES )

SANTA ROSA CITY, LAGUNA ) S.S.
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COMPLAINT-AFFIDAVIT

I, PERSON A, of legal age, Filipino and a resident of B168 L48 Ambrocia

Subd. Brgy. Ibaba, Santa Rosa Laguna, after having been sworn to in
accordance with law hereby depose and state:

1. That am accusing PERSON B a resident of Barangay Dita, Santa

Rosa, Laguna of THEFT.

2. That on April 1, 2018, I was cleaning my farm;

3. That on that same date, I realized that my only cattle was lost
which I had placed at the farm;

4. As standard procedure, I verbally reported the incident to the

Barangay Officials;

5. April 7, 2018, a friend of mine, Gian Madrid noticed that

PERSON B had a new cattle which was very similar to the one I
lost;

6. That on that same date, I confronted PERSON B having

possession of a stolen cattle;

7. That on April 8, 2018 around 5:30am in the morning, PERSON B

went to my farm and brought the cattle in his possession;

8. At this juncture, myself, MR. GIAN MADRID, a friend of mine and

PERSON B examined the cattle to check its identity and verify if
its matches my lost cattle;

9. Upon checking the cattle, we found out that it was a complete

match;
10. When we asked PERSON B why he stole my cattle, he denied
stealing the same, and argued that he bought the cattle,
furthermore he refused to return the cattle to me;

11. Respondent PERSON B, despite my objection, asked us to allow

to him to get the receipt that he indeed bought the said cattle,
and the Certificate of Ownership of the Cattle, however he
never returned nor did he show proof of his rightful ownership
of the cattle;

12. Later on, he informed me that he had lost the cattle;

THEFT

Art. 308. Who are liable for theft. — Theft is committed by any
person who, with intent to gain but without violence against or
intimidation of persons nor force upon things, shall take
personal property of another without the latter’s consent.

Theft is likewise committed by:

Any person who, having found lost property, shall fail to

deliver the same to the local authorities or to its owner;

13. That attached hereto as Annexes to prove the elements of

the crime of theft:

“A” – Certificate of Ownership of the cattle indicating the name

of the owner and its respective details;

“B” – Sworn Affidavit of Team Leader GIAN MADRID, to prove

and attest that the cattle in possession of PERSON B matches
the cattle I am raising;

“C” - Signed statement of GIAN MADRID dated April 7, 2018;

“D” – Incident Report dated April 1, 2018 which I sent to our

Barangay Officials to report that a PERSON B is in possession of
a cattle which was very similar to the one stolen from me;

“E”- Photographs of the stolen Cattle;

 That I am executing this Complaint-Affidavit for the purpose of filing
the complaint for THEFT against PERSON B.

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

April 2018, in Santa Rosa City, Philippines.

PERSON A
Complainant/Affiant

SUBSCRIBED AND SWORN TO before me this _____ day of April, 2018,

in Santa Rosa City, Philippines, and hereby certify that I have personally
examined the Affiant and I am satisfied that he voluntarily executed and
understood his complaint affidavit

Assistant City Prosecutor