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Complaint-Affidavit-Sample

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REPUBLIC OF THE PHILIPPINES )
CITY OF SAN JUAN ) s.s
COMPLAINT-AFFIDAVIT
I, FRANCESCA MANUEL, of legal age, Filipina, with assistance of counsel, and resident
of 887 Kentucky Apartments, 88th Street, Brgy. 88, San Juan City, do hereby state under oath that:
1. I am the owner of one (1) heart-shaped pair of earrings with diamond, one (1) heart-shaped
ring with diamond, and one (1) white gold bracelet with diamond stones worth Php 650,000.00
(“Jewelry”).
2. I accuse and hereby charge JOLEENA MAGDASAL (MAGDASAL), owner of “Bujoy’s
Jewelry”, a Jewelry Store in Greenhills Shopping Center, San Juan City, situated on the ground
floor in the south portion of the mall, with a signage board bearing the name “Bujoy’s Jewelry,”
for violation of P.D. 1602, also known as the Anti-Fencing Law of 1979, for engaging in the
illegal act of selling with intent to gain, of the Jewelry, which are the proceeds of theft.
3. I came to know of the presence of my Jewelry at “Bujoy’s Jewelry” from my cousin
YSOBEL MANUEL (MANUEL), who brought the fact to my attention, she having
recognized them as mine.
4. I have positively identified the Jewelry as the very same Jewelry in my complaint as a result
of previous surveillance work with the police, having spotted the initials “RM” engraved on
the ring, which are the initials of my grandmother, when I pretended to be an interested buyer.
5. MAGDASAL herself has admitted when questioned about the origins of the jewelry that it
came from one MAGDALENA DACOT (DACOT), an aunt who requested her to sell such
jewelry and for which MAGDASAL would get a 20% commission.
6. Unknown to MAGDASAL, I lived in a room in an apartment owned by my former
landlady, the very same person who brought the Jewelry to her (DACOT), whom I
subsequently filed a case of Theft against for the unlawful taking of the jewelry.
7. On the basis of said investigation and surveillance operation by the police, there is a wellfounded belief that MAGDASAL is indeed engaged in the sale of goods which she knows or
should have known were derived from the proceeds of the crime of theft in violation of P.D.
1602 or the Anti-Fencing Law of 1979.
8. Police officials who were involved in the application of the search warrant have personally
verified the report through surveillance and investigation activities together with SPO1
MARIO AGUSTIN and MANUEL, to ascertain the veracity thereof and found the same to
be true and correct.
IN TRUTH HEREOF, I hereunto affix my signature this 27th day of August 2018 at San
Juan City.
FRANCESCA MANUEL
Complainant-Affiant
SUBSCRIBED AND SWORN TO BEFORE ME this 27th day of August 2018 at San
Juan City, Metro Manila.
ANDY MUHLACH
Investigating Prosecutors
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