REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR

xxxxxxxxxxxxxxxxxxxxxxxx
Complainant,

-versus- NPS Docekct No.

xxxxxxxxxxxxxxxxxxxxxxxxxxxx
Respondents.

x----------------------------------------------------------------------
--------x

REPLY-AFFIDAVIT
x

I, xxxxxxxxxxxxxxxxxxx, of legal age, single mother, Filipino

and a resident1 of xxxxxxxxxxxxxxxxxxxxxxx., Barangay, San Pedro,
Sto. Tomas, Batangas, after having been sworn to in accordance with
law do hereby depose and state:

1. That I am instituting this criminal complaint against

xxxxxxxxxxxxxxxxxxxxxxxx, both of legal age; Filipinos, and
residents of xxxxxxxxxxxxxxxxxxxx respectively, for
xxxxxxxxxxxxxxxxxx;

2. That the acts complained of were committed as follows:

a. On January 30, 2019 after one (1) year and six (6) months
of working as I resigned as a store manager of
xxxxxxxxxxxxxxxxxxx franchise owned and operated by
xxxxxxxxxxxxxxxxxx, located at xxxxxxxxxxxxxxxx.

b. Sometime in February 2019, I asked

xxxxxxxxxxxxxxxxxxxx the present store manager that I
need a certificate of employment which I will be using for
 my job application as reference , however I was prevented
by the owner xxxxxxxxxxxxxxxxxxxxxxx from entering
the premises of the store for unknown reasons, as far as I
know I have done nothing wrong to her and the store
during my stint as the store manager;

c. On February 22, 2019, I was able to get a certificate of

employment with xxxxxxxxxxxxxxxxxxxx and took that
opportunity to turn over whatever I left in the
xxxxxxxxxxxxxxxxxx convenience store as a previous
store manager to have my clearance, however I was not
given a clearance despite the indorsement I made to the new
manager xxxxxxxxxxxxxxxxxxx;

d. On February 28, 2019, I was informed by the owner mam

xxxxxxxxxxxxxxxxxxx thru text messages, that there was a
problem with the store, it had series of cash shortages in the
cash register, which respondents are saying that I am the
one who took the cash;

e. I was shocked in disbelief because all I know that when I

left the store on January 30, 2019 the store had a surplus
and I had nothing to do with the cash shortage;

f. Stunned by what Mam xxxxxxxxxxxxxxxxxxxxxx

information, I asked some of my former workmates
including respondents herein and told them that mam
xxxxxxxxxxxxxxxxxxwas so infuriated at me because of
the cash shortage that occurred in the store which I have
nothing to do with it, but respondents kept mum about it;

g. Sometime in March 2019, my relatives who reside in

Barangay Banadero, told me that respondent’s where
spreading news that I was a thief to be exact they said that “
xxxxxxxxxxxxxxxxxxxxxxxxxxxxx”;

h. At first I do not want to believe it because they were my

friends and co-employees whom I trust, so I did not mind
about it, however my friend xxxxxxxxxxxxxxxx informed
me that the respondents where spreading it with everyone
 in xxxxxxxxxxxxxxxxxxxxxxx, alarmed about the
information I asked my previous co-workers at
xxxxxxxxxxxxxxxxxxxx store and to my surprise the acts
of respondent in spreading that I am a thief, that I stole
money from xxxxxxxxxxxxxxxxxxxx convenience store is
true and real;

i. So, I filed a case before the Lupon of Barangay Banadero

wherein the respondents admitted before the Lupon that
they actually uttered those malicious and baseless
accusations / statements against me without any basis at all,
which made me realize that they are the one who told my
former boss Mam xxxxxxxxxxxxxxxxxxxxxxxx, that I was
the one who took the money that caused the shortage of
cash in the cash register which mam xxxxxxxxxxxxxx
informed me last February 28, 2019 in a series of text
messages, attached herewith is a copy of the Certificate to
file action as Annex “A”;

3. That, from the foregoing, respondent’s acts against me and their

malicious utterances “
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx” was made to
cover up for their shortages where I have no knowledge or
participation;

4. That, respondents intention was to destroy, discredit, ridicule and

humiliate my reputation as an individual before the bar of public
opinion;

5. That, I received negative remarks from my neighbors, co-

workers, even my own child was not spared in expressing belief
with respondent’s baseless and malicious imputations against me
to my damage and prejudice;

6. That, I suffered sleepless nights, moral and social embarrassment;

7. That I am executing this affidavit to attest to the truth of the

foregoing averments and for the purpose of criminally
prosecuting xxxxxxxxxxxxxxxxxxxxxxxx .
 IN WITNESS WHEREOF, I have affixed my signature this
xxxxxxxxxxxxxxxxxxx City.

xxxxxxxxxxxxxxxxxxxx
Complainant/Affiant

SUBSCRIBED AND SWORN to before me in the

xxxxxxxxxxxxxxxxxxxxx this 22nd day of July 2019. I hereby certify
that I have personally examined the above named affiant and that I am
the foregoing statements were given by her voluntarily and of his own
free will.

_______________________
Investigating Prosecutor