Republic of the Philippines) S.

S
City of Tarlac )

AFFIDAVIT COMPLAINT

I, ROSE ANN A. KUMAR, of legal age, Filipino, businesswoman, and with

business at A square building Sitio Tanpoco, Brgy. Matalaib Tarlac City after
having been duly sworn to in accordance with law, do hereby deposes and states
that:

a. I am the owner/proprietor of EY-EN-EN GENERAL MERCHANDISE,

with principal place of business A square building Sitio Tanpoco, Brgy.
Matatalaib Tarlac City.

b. On 1 October 2018, Lea Soley (Subject for brevity), 168 San Pedro Pura
Tarlac, went to my business address mentioned above and threat, received in
trust assorted merchandise/items valued at Eighteen Thousand Five Hundred
Seventy Pesos (Php18,570.00), specified in the Trust Receipt Agreement.

c. All assorted merchandise/items were entrusted to Subject, with obligation to

turn over to me the proceeds of the sale thereof, or if unsold, to return the
items within the specified period agreed upon. (attached is the copy of the
Trust Receipt Agreement dated 1 October 2018 marked as Annex “A” and
made an integral part hereof)

d. When the Trust Receipt fell due, I required the payment for the
merchandize/items by means of a demand letter but it was to no avail.
(attached is the Demand Letter marked as Annex “B”, and made an integral
part hereof)

e. Despite the receipt of a demand letter thru Philippine Postal Office, Subject
failed to pay or deliver the merchandise/items or proceeds to me. Worst, I
found out the merchandise/items entrusted to Subject were already disposed
of and she had misappropriated, misapplied, and converted the said
merchandise/items or the value thereof, to her own personal use and benefit,
to my damage and prejudice, in the aforesaid amount. (attached is the copy
Registry Return Receipt marked as Annex “C”, and made an integral part
hereof)

I am executing this Complaint Affidavit to lodge a case of Estafa/Swindling,

punishable under the provisions of Article 315, paragraph 1(b), of the Revised
Penal Code, as amended, against LEA SOLEY, and to attest to the veracity and
truthfulness of the foregoing statement.
AFFIANT FURTHER SAYETH NAUGHT.

IN WITNESS WHEREOF, I have hereunto set my hands

this________________________ at the Cabanatuan City, Department of Justice,
Cabanatuan City.

ROSE ANN A. KUMAR

Affiant

SUBSCRIBED AND SWORN to before me

this________________________, at the Cabanatuan City, Department of Justice,
Cabanatuan City.

I hereby certify that I have personally examined herein Affiant and I am

fully satisfied that she freely and voluntarily executed her statement and
understood the same.

__________________________