Complaint-Affidavit Qualified Theft

Republic of the Philippines)
Aurora, Zamboanga del Sur ) S.S.
HARUNO SAKURA,
Plaintiff
- versus –
HYUGA HINATA,
HYUGA NEJI
Defendant
x----------------------------x
COMPLAINT-AFFIDAVIT
I, HARUNO SAKURA, single, of legal age, Filipino citizen and a resident of Lireo,
Zamboanga del Sur after being duly sworn in accordance with law do hereby depose and state
that:
1. I am the plaintiff in this matter and have personal knowledge of the matters herein
referred to.
2. On May 03, 2021, around 5 o’clock in the evening, before leaving my establishment
at Poblacion, Lireo, RABIYA GADGETS AND ACCESSORIES, I entrusted the keys
of my product vault and door roll up to my hired saleswoman for 4 years, HYUGA
HINATA and the key to my motorcycle used for delivery to my hired janitor/delivery
man for 2 years HYUGA NEJI, with much confidence asking them to lock and secure
the gadgets and equipment inside the establishment after the sales inventory and
clean up.
3. That accused HYUGA HINATA, single, of legal age, Filipino citizen and a resident
Lantungan, Lireo, Zamboanga del Sur, where she may be served with summons and
other relative legal processes thereto.
4. That accused HYUGA NEJI, single, of legal age, Filipino citizen and a resident
Lubid, Lireo, Zamboanga del Sur, where he may be served with summons and other
relative legal processes thereto.
5. At around 8 o’clock that evening, I called HYUGA HINATA to make sure she has
already locked the establishment but she did not answer her phone. I also called
HYUGA NEJI to ask if they are done, but to no avail, his phone is unattended.
6. That on or about 3rd of May 2021, at about 8;30PM, in the municipality of Lireo,
Province of Zamboanga del Sur and within the jurisdiction of this Honorable Court,
the said accused HYUGA HINATA and HYUGA NEJI did there and then voluntarily,
unlawfully, and feloniously had, voluntarily, unlawfully committed the crime of
Qualified Theft punishable under Article 310 of the Revised Penal Code.
7. On May 04, 2021, at around 7 o’clock in the morning, I went to the establishment and
was surprised because my saleswoman HYUGA HINATA and janitor HYUGA NEJI
had not yet arrived.
8. When I was about to call both of them, the employee named Daniel of the nearby
Ogis Lechon Manok passed by so I asked him if he had seen HYUGA HINATA and
HYUGA NEJI. He said he had not seen them that morning but had seen the two last
night. She was carrying a backpack and she was rushing. Instead of a passenger
jeepney, she rode a bicycle saying ‘UNHAN KA NAKO DONG KAY AKO PA NI
IHATOD SA GA-ORDER.” While the janitor HYUGA NEJI left the building 10
minutes later without a word riding the motorcycle I owned intended for order
deliveries. (Affidavit of witness, Mr. Daniel Padaplin is hereto attached as “ANNEX
A”);
9. After the brief conversation and inquiry with the lechon manok employee of the
nearby establishment, using the duplicate key, I opened my establishment. I noticed
that valuable items were missing: 3 Samsung Galaxy S21 Ultra 5G with product
serial key 212134, 2121678 and 2121234 respectively, each valued at P70,000.00; 2
iPhone 12 Pro Max each valued at P75,000.00, 2 Huawei Mate 40E each valued at
P35,000.00 and Yamaha NMAX valued at P120,000 with the total amount of
P550,000, Philippine Currency.
10. After discovering that the phones and motorcycle are missing, I called HYUGA
HINATA and HYUGA NEJI many times but both could no longer be reached. They
are alone in the establishment and the key to the vault and motorcycle was entrusted
to them, they had free access to the items which they carried away. I had also never
asked them to deliver gadgets to our customers.
11. 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
HYUGA HINATA and HYUGA NEJI and for any legal purposes it may serve.
IN WITNESS WHEREOF, I have hereunto set my hand this 5th day of May 2021
at Lireo, Zamboanga del Sur, Philippines
HARUNO SAKURA
Affiant
SUBSCRIBED AND SWORN to before me, this 5th of May 2021, by HARUNO SAKURA
who exhibited to me (his/her) Community Tax Certificate No. 211816 issued at Lireo,
Zamboanga del Sur, Philippines on 5th of May 2021.
UCHIHA SASUKE
Counsel for the Plaintiff
PTR No. 2111816
IBP No. 86534332
Roll No. 34567
Room 24, Japan 3rd Floor Building, Lireo, Zamboanga del Sur
Notary Public
Doc. No. ______;
Page No. ______;
Book No. ______;
Series of ______;

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Republic of the Philippines)

Aurora, Zamboanga del Sur ) S.S.

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