“pHa
Republic of the Philippines
Department of Justice
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
ANGELES CITY, PAMPANGA
INVESTIGATION DATA FORM
To be accomplished by the Office:
NPS DOCKET NO:
Bony -OQ) = Gorge
Assigned to:
Date Assigned:
_To ‘beSccomplished by complainanv/counsellaw enforcer:
COMPLAINANT/s: Name, Sex, Age &
Address:
LANILA EXPLORATION CO-ANNEX, LTD
REPRESED ROSARI
MAYA-MAYA, and with address at #35-8
Sarita Street, Diamond Subdivision, Brgy.
Nalibago, Angeles City, Pampanga
OFFENSE/s COMMITTED / LAW/s
VIOLATED:
Qualified Theft under Art. 310 of the Revised
Penal Code
DATE & TIME of COMMISSION:
April 2007; October 2008
1 Has a similar complaint been filed before any other office?”
2s this complaint in the nature of @ counter-charge?*
3 ls this complaint related fo another case before this office?”
(Use back portion if space is not sufficient)
RESPONDENT/s: Name, Sex, Age & Address:
TONY BRYAN HORN, and with address at
Sapang Biabas, Dau, Mabalacat, Pampanga
WITNESS/es: Name & Address
SHAYNE FAIRBANKS and JONATHAN B.
CRUZ, both with office address at #35-8 Sarita
Street, Diamond Subdivision, Brev. Balibago,
Angeles City, Pampanga
PLACE of COMMISSION
Angeles City
YES ___ NO_X_
YES ___ NO _X_ It yes, indicate details below
YES ___ NO_X_ if yes, indicate details below:
CERTIFICATION*
(Song:
P
RIBED AND SWORN TO before me this__1Q* _day of i be
lf fe
| CERTIFY, under oath, that al the information on this sheet are tue and correct to the best of my knowiedge and
Ihave not commenced any ection of fled any cleim involving the seme issues in any court, tibunal, or quasi-
‘agency, and that if| should thereafter learn thet a similar action has been fled and/er is pending, | shail report that
to this Honorable Office within five (5) days from my knowledge thereof,
LEAH DEL REPUBLIC OF THE PHILIPPINES
DEPARTMENT OF JUSTICE
OFFICE OF THE PROVINCIAL PROSECUTOR
Angeles City, Pampanga
MANILA EXPLORATION CO. -
ANNEX, LTD. (represented by LEAH C.
DEL ROSARIO-MAYAMAYA),
‘Complainant,
= versus ~ 1S.No.
For: QUALIFIED THEFT
TONY BRIAN HORN
Respondent.
REPUBLIC OF THE PHILIPPINES )
ANGELES CITY, PAMPANGA =) SS.
COMPLAINT-AFFIDAVIT
I, LEAH C. DEL ROSARIO-MAYAMAYA, 0 legal age, married, Filipino, and
with office address at #35-8 Sarita Street, Diamond Subdivision, Brgy. Balibago,
Angeles City, Pampanga, having been duly sworn to in accordance with law, hereby
depose and state:
1. am the authorized representative of MANILA EXPLORATION CO. -
ANNEX, LTD. (“MECO”), a Limited Partnership duly organized and existing under
Philippine laws, with business addresses at Unit 1116 Cityland Shaw Tower, Saint
Francis Street corner Shaw Bivd,, Mandaluyong City, Metro Manila and #35-8 Sarita
Street, Diamond Subdivision, Brgy. Balibago, Angeles City, Pampanga. | am duly
authorized to execute this Complaint-Aifidavit in behalf of MECO by virtue of the
Special Power of Attorney dated 16 October 2009 which was executed by Matilde R
Haynes (’Ms. Haynes”) and Partnership Resolution dated 16 October 2009 which were
executed by Ms. Haynes and Mr, Norman Haynes (Mr. Haynes”), limited partner of MECO. Copies of the Special Power of Attorney and Partnership Resolution are
respectively attached hereof as Annexes “A and “BY.
2 MECO is principally engaged in the business of conducting exploratory
Grilling, electronic prospecting, and excavatory search for the ultimate recovery of
potable water, or precious metals, and other valuables located upon, within or below
Privately owned real estate, public lands/waters, and real estate purchased by MECO,
and any other acts, activities or undertaking reasonably required or necessary to carry
out the foregoing purposes. A copy of MECO’s Article of Partnership is attached hereof
as Annex “C”,
3. __A former consultant of MECO is Respondent MR. TONY BRIAN HORN
( Respondent’), an American National and a pastor of Trinity Baptist Church
Respondent's last known postal address is at Sapang Biabas, Dau, Mabelecat,
Pampanga.
4. Sometime in the second quarter of 2007, Respondent entered into an oral
consultancy agreement with MECO through one of its partners, Mr. Haynes
Respondent worked with MECO for more than one (1) year as consultant and adviser
on matters relating to the business activities, undertaking and operations of MECO. As
consultant, Respondent had been entrusted with the management of MECO’s branch
oifice in Angeles City, Pampanga, especially when Mr. and Ms. Haynes were either in
their Quezon City office or outside the Philippines meeting with prospective investors
of MECO. Respondent is also charged with the custody of funds for the daily operation
of MECO and has a hand in the preparation of MECO’s employee payroll.
5. Thus, Respondent inevitably had access to the business files and
documents of MECO, including those stored in the computer, considering that Mr. and Ms. Haynes fully reposed their trust and confidence to Respondent, owing to the fact
that Respondent was a pastor and is actively taking part in Bible Missions all over the
country.
6 Sometime in the month of April 2007 and onwards, several of MECO’S
office files and documents, such as its payroll register and contract of employment
began to disappear and were unaccounted for. Although there were some rumors
circulating within the office of MECO in Angeles City, Pampanga that Respondent was
the one who surreptitiously took the missing files, Mr. and Ms. Haynes did not believe
then that Respondent is capable of doing such despicable acts. However, the talks
among the employees privy in the day to day operation of MECO in its Angeles City
office had persisted, pointing to Respondent as the culprit in the disappearance of
MECO’s files, In fact, one of the employees of MECO, Ms. Shayne A. Fairbanks (Ms.
Fairbanks”), the personal secretary of Mr. Haynes, personally saw Respondent took out
her files and documents from her drawer without her consent and that of the Company.
Upon inspection of her drawer she found out that MECO’s SEC Certificate of
Registration, land titles, official reveipt/certificate of registration of several cars, and
other documents were already missing. A copy of Ms. Fairbanks’s Swom Affidavit
dated 16 October 2009 attesting to the foregoing incidents is attached hereof as Annex
“DY.
7. It must be emphasized that Ms. Fairbanks personally reported the afore-
mentioned incidents to Mr. and Ms. Haynes. Since then, Mr. and Ms. Haynes became
wary of the real motive of Respondent in taking out MECO’s files without their
knowledge and consent, considering that, as confided by Mr. and Ms. Haynes to Ms.
Fairbanks, Respondent, on various occasions, told them that he wanted to resign. Thus, Iwas told heard Mr. and Ms. Haynes instructed Ms. Fairbanks to be on guard and keep
a close watch of Respondent's activities in the office.
8 On October 2009, Mr. and Ms. Haynes finally decided to accept the long
overdue resignation of Respondent. Thus, when Respondent arrived from his vacation
in Israel, he was accordingly told that his resignation was accepted and he has until the
end of the month to move out his personal things from the office.
9 Shortly after Respondent left MECO, an inventory audit was conducted
by the MECO’s INVENTORY DEPARTMENT. In the said audit, it was found out that
several important files and documents were missing. Likewise, two (2) units of Clone
Notebook laptops and a desktop computer with their corresponding accessories were
unaccounted for. At this point, Mr. and Ms. Haynes investigated and confronted MECO
employees regarding the missing office files, documents, and the laptop and desktop
computers. Thereupon, Ms. Geene F. Villareal (“Ms. Villareal”), Ms. Riena Rose M.
Valencia (Ms. Valencia”), including Ms. Fairbanks, revealed that on various occasion
they respectively saw Respondent, alone or accompanied by his personal assistant Mr.
Neal Cortez (Mr. Cortez”), took out the hard drive of the computer, copied MECO’s
files therein using a USB Memory stick, and that some important papers under the
castedy of Ms. Fairbanks were handed by her to Respondent upon the request of the
latter. When asked by Mr. and Ms. Haynes why they did not immediately report these
incidents to them, Ms. Villareal and Ms. Valencia answered that they did not directly
report the incidents to them then because they were afraid of what Respondent might
do. Knowing that Respondent was managing the affairs of MECO at that time, and the
fact that Mr. and Ms. Haynes were blindingly convinced of Respondent's sincerity, Ms
Villareal and Ms. Valencia opted to remain silent rather suffer the resulting
consequences if they revealed Respondent's criminal acts. 10. In addition, attached hereof is the Swom Affidavit of MECO’s Secanty
Guard jonathan B. Cruz (“Mr. Cruz”) as Annex “E*, attesting to the fact that sometime
‘on October 2008 he saw Respondent coming out from the office with a computer and
some assorted documents and loaded the same into his car.
11. Consequently, MECO, on several occasions demanded to Respondent that
he return the missing documents, two (2) units of Clone notebook laptops, and a
desktop computer, with their corresponding accessories what he stole from the
company. However, the Respondent obstinately refused to return afore-mentioned
items.
12, Indeed, the missing office files and documents and computers with their
accessories were surreptitiously taken out by Respondent from MECO’s office in
Angeles City, Pampanga, as the same were inadvertently seen by me in the house of
Respondent at Sapang Biabas, Dau, Mabalacat, Pampanga when I visited him on 28
September 2008. In fact, I told Respondent to return the items he took from the office,
but he got mad and threatened me with serious physicai harm, and ordered me to leave
his house immediately. A copy of my Swarn Affidavit attesting to the foregoing facts is
hereto attached as Annex “G*.
13. Upon learning this, Mr. and Ms. Haynes instructed me to seek police
assistance so that the missing items may be retrieved from the Respondent. Hence, I
vient to the Philippine National Police-Regional Special Operations Group (PNP-
RSOG), PROS, Camp Olivas, San Fernando, Pampanga where I was thoroughly
investigated under oath by Police Inspector Norberto S. Murillo (“Insp. Murillo”).
Attached hereof as Annex “HY, is a copy of the Special Power of Attorney (“SPA)
dated 20 September 2009 executed by Mr. and Ms. Haynes authorizing me to undertake ‘pecescary action in the application of search warrant for the recovery of MECO’s office
les, computer accessories and computers This SPA was executed beforehand by Mr.
and Ms. Haynes on the basis of the reports made by Ms. Fairbanks, Ms. Villareal, Ms
Valencia and Mr. Cruz that Respondent was the one who maliciously took MECO’s
missing office files and computers with their accessories, in anticipation of the
confirmation that the missing items were really in the custody and contro! of
Respondent.
14. Convinced that I was telling the truth, Insp. Murillo lost no time to apply
for search warrant with the Regional Trial Court-Third Judicial Region, Guimba, Nueva
Ecija, which application for search warrant was granted by the Honorable Executive
Judge Ramon D. Pamular. Copies of the Application for Search Warrant dated 01
October 2009, Honorable Executive Judge Ramon D. Pamular’s Order dated 01 October
2009 granting the Application for Search Warrant dated 01 October 2009, and the Search
Warrant itself dated 01 October 2009 are attached hereof as Annexes “I”, “J”, and “K”,
respectively.
15, _ Immediately thereafter, the team of Insp Murillo proceeded to the house of
Respondent at Sapang Biabas, Dau, Mabelacat, Pampange and served with him the
Guly issued Search Warrant. Resultantly, the searched had yielded the following items,
namely.
1. Two (2) units Clone Notebook Laptop with MECO Database /Hard
Drives
Personal Desktop Computer with MECO File Hard Drive
Records Hard Drives
Two pieces USB Memory Stick
CD's/Diskettes
Stocks, Expenses and Financial Transaction Ledgers
Certificate of Partnership
Records of Partnership Participation
Investors Database
SOPH Or Oo f 30. Employment Contracts
1 Other assorted MECO/OPSEC files
16 Copies of the pertinent documents relating to the execution of the search
warrant at Respondent's house at Saparig Biabas. Dau, Mabalacat, Pampanga consisting
of the following, namely, 1) Certification of Orderly Search issued by (PNF-RSOG),
PROS, Camp Olivas, San Fernando, Pampanga, 2) Seizure Receipt issued by (PNF-
SOG), PRO3, Camp Olivas, San Fernando, Pampanga, and 3) the Pinagsama-samang
simumpaang Salaysay dated 01 October 2009 executed under oath by Insp. Murillo,
SPO! Bello Q. Borqueta and SPO1 Herman M. Limaya are attached hereof as Annexes
“4, "MM", and “N", respectively.
17. Consequently, a criminal Complaint for Qualified Theft under Article 310
of the Revised Penal Code was filed against Respondent before the Office of the
Provincial Prosecutor of San Fernando, Pampanga. However, in the Resolution dated 7
Cetober 2009 which was issued by Assistant Provincial Prosecutor Caliopel L- De
Guzman, the Complaint for Qualified Theft under Article 310 of the Revised Penal Code
against the Respondent was dismissed, because the Office of the Provincial Prosecutor
of San Fernando, Pampanga allegedly has no jurisdiction to take cognizance of the
case. Attached as Annex “O”, is the Resolution dated 07 October 2009. .
18. Hence, this present Complaint for Qualified Theft under Article 310 of the
Revised Penal Code is hereby filed before this Honorable Office.
39, Without a doubt, Respondent is criminally liable for Qualified Theit under
Article 310 of the Revised Penal Code, to wit
“Art, 310. Qualified theft. - The crime of theft shall be
punished by the penalties next higher by two degrees that
ee ~ scely epecified in the next preceding article, if confidence, x x x x x x x [Emphasis and underscoring
supplied ]
20. Moreover, theft as defined under Art. 308 of the Revised Penal Code
“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,
sh al property of another without the latter's
consent.
XxX xx xxx xxx” [Emphasis and underscoring
supplied]
21, In the case of Ferdinand A. Cruz vs. The People of the Philippines, GR. No.
176504, 03 September 2008, the ruling of the Supreme Court was instructive, to wit:
“The elements of the crime of theft are the following: (1)
there was a taking of personal property; (2) the property
belongs to another; (3) the taking was without the consent of
the owner, (4) the taking was done with intent to gain; and
(3) the taking was accomplished without violence or
intimidation against the person or force upon things. Under
Article 310 of the Revised Penal Code, theft is qualified
when it is, among others, committed with grave abuse of
confidence, to wit:
ART. 310. Qualified thef. - The crime of theft shall be
punished by the penalties next higher by two degrees than
those respectively specified in the next preceding article, if
committed x x x with grave idence xxx.
The prosecution established, beyond the shadow of doubt
that Ferdinand took and kept the fifteen thousand peso-
collection from the company’s client. Although Ferdinand
insists he remitted the amount personally to Luningning,
this claim is self-serving. If indeed he personally delivered
the P15,000.00, he would have at least required Luningning
to acknowledge the receipt thereof before he parted with
the same. The Court of Appeals incisively pointed out that
it was implausible for Ferdinand to have acceded to
executing an acknowledgment receipt in favor of
Hemisphere so as to give the latter protection from his
company, and yet he did not ask for some kind of receipt
when he allegedly turned over the money to Luningning.
Quite specious is Ferdinand’s argument that he would not have had in his possession a copy of Official Receipt No.
2242, had he not delivered the amount to Luningning.
Ferdinand acquired the receipt, not because he remitted
the amount, but because he took a sheet from a booklet of
receipts containing Official Receipt number 2242 and
issued the same to Hemisphere despite his lack of
authority to do so, to maliciously induce the client into
believing that he would remit the amount to Porta-Phone.
The collected amount belonged to Porta-Phone and not to
Ferdinand. When he received the same, he was obliged to
tum it over to the company since he had no right to retain
it or to use it for his own benefit, because the amount was
a refundable deposit for the communication items leased
out by Porta-Phone to Hemisphere. As he had kept it for
himself while knowing that the amount was not his, the
presence of the element of unlawful taking is settled.
Intent to gain (animus lucrandi) is presumed to be alleged
in an information, in which it is charged that there was
unlawful taking (apoderamiento) and appropriation by the
offender of the things subject of asportation. In this case, it
was apparent that the reason why Ferdinand took the
money was that he intended to gain by it. In the meeting
held on 30 October 1996, Ferdinand admitted having
received the amount and kept it until his reimbursements
from the company would be released to him. x x x x
The lack of consent by the owner of the asported money is
manifested by the fact that Porta-Phone consistently
sought the return of the same from Ferdinand in the
meetings held for this purpose and in the various letters
issued by the company.
As a marketing manager of Porta-Phone, Ferdinand made
use of his position to obtain the refundable deposit due to
Porta-Phone and appropriate it for himself. He could not
have taken the amount had he not been an officer of the
said company. Clearly, the taking was done with grave
abuse of confidence.” [Emphasis and underscoring
supplied]
Verily, the elements of Qualified Theft are as follows:
(a) That there be taking of personal property;
(©) That said property belongs to another; (d) That the taking be done without the consent of the
owner;
(©) That the taking be accomplished without the use of
violence against or intimidation of persons or force upon
things; and, lastly,
(9 For theft to be qualified, the theft must be committed
with grave abuse of confidence. [Luis B. Reyes, Revised
Penal Code, Book II, 16% edition, 2006.]
23. On the first element, the subject business files and documents, computer
laptops, desktop and computer accessories are clearly personal properties.
24. On the second element, the subject business files and documents,
computer laptops, desktop and computer accessories are without doubt, owned by
MECO.
25. On the third element, the taking of the subject business files and
documents, computer laptops, desktop and computer accessories by Respondent is
definitely for the purpose of gain. It must be noted that the two (2) units Clone
Notebook Laptop and the desktop computers, by themselves, are of substantial value
amounting to at least ONE HUNDRED FIFTY THOUSAND PESOS (P150,000.00).
26. On the fourth element, Respondent took these personal properties without
the consent of MECO. In fact, based on the evidences attached in this Complaint, it is
without doubt that Respondent took the subject business files and documents,
computer laptops, desktop and computer accessories, in a furtive manner, and without
any authorization or consent of MECO. 27, As to the fifth element, the stealing of the subject business files and
documents, computer laptops and desktop and computer accessories, was done
deviously, with stealth and not through the use of force or violence.
28. Lastly, the Respondent is criminally liable for Qualified Theft under Art
310 of the Revised Penal Code because his act of stealing MECO’s property wes
committed with grave abuse of confidence reposed upon him by MECO. Being a
consultant and the fact that he is a personal friend of Mr. and Ms. Haynes, he was given
fall trust and confidence by them to carry out his consultancy and administrative
fanction in MECO with complete leeway and freedom. However, with the intention of
gaining profit for himself and without the knowledge and consent of MECO,
Respondent took, stole and carted away with the subject items. The stolen items,
excluding the business files and documents, amount to at least ONE HUNDRED FIFTY
THOUSAND PESOS (P150,000.00).
29. Asa recult of Respondent's unlawful acts and omissions, MECO incurred
actual damages on account of the theft of its properties amounting to ONE HUNDRED
FIFTY THOUSAND PESOS (P150,000.00).
30. To deter others from emulating Respondent's lead, exemplary damages in
the amount of at least FIFTY THOUSAND PESOS (P50,000.00) should be awarded to
MECO.
31. — To protect its interest, MECO had been constrained to institute the instant
suit, for which it has incurred and expects to incur, expenses for litigation and
attorney's fees in the amount of at least THREE HUNDRED THOUSAND PESOS
(F300,000.00). 32. For purposes of service of subpoena and other processes, the last known
address of Respondent MR. TONY BRIAN HORN is at Sapang Biabes, Dau, Mabalacet,
Pampanga.
33. The foregoing facts occurred within the jurisdiction of this Honorable
Office considering that the acts constituting the offense of Qualified Theft occurred
within the jurisdiction of Angeles City, Pampanga, and Respondent took the subject
personal properties from the office of MECO in Angeles City, Pampanga.
34. This Complaint-Affidavit has been executed to support the filing of a
criminal case against MR. TONY BRIAN HORN for Qualified Theft under Article 310 of
the Revised Penal Code
Further, Affiant sayeth naught.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 19° day of
October 2009 at Angeles City, Pampanga, Philippines.
Nima i
LEAHC. iL iO-MAYAMAYA
Affiant
SUBSCRIBED AND SWORN to before js 19% day of October 2009 at
Angeles City, Pampanga.
This to certify that Ihave personal thentioned Complaint-
Affidavit; that I am satisfied that the AGke and that she
executed the same of her own free will.
OUyER C. SISON
cpetial Counsel
ide of the City Prosecutor
Angeles Gity gay een a
ANNEX”
SPECIAL POWER OF ATTORNEY
1, MATILDE HAYNES, Filipino, of legal age, General Manager of
MANILA EXPLORATION CO. - ANNEX LTD., INC. (“Company”), with
business address at Cityland Shaw Tower Unit 1116 St. Francis Street comer
Shaw Boulevard, Mandaluyong City, Philippines, hereby name, constitute and
appoint LEAH DEL ROSARIO MAYAMAYA or any employee authorized in
writing by the Company's President or General Manager and the law firm of
Nicolas & De Vega Law Offices and its designated representatives, lawyers and
attorneys, as my true and lawful attorneys-in-fact and counsel, and in my name,
place and stead, to represent me in any proceedings before any Judicial, Quasi-
judicial, and/or Administrative agency, body, office or tribunal including the
Regional Trial Court, Metropolitan Trial Court, Municipal Trial Court, Municipal
Trial Court in Cities, as well as any and all Appellate courts, tribunals, bodies,
agencies or offices and (i) to further represent me in any pze-tial, mediation or
preliminary conference and other proceedings in connection with any case
involving the Company or any of its partners, officers, members, representatives
and employees with full power to do and perform on my behalf any act or deed
which I could legally do and perform, if personally present at the pre-trial,
mediation or preliminary conference and such other proceedings; (Ii) to sign,
verify and file any and all pleadings or motions in connection with any case
involving the Company or any of its partners, officers, members, representatives
and employees, and certify that I have complied, and will comply, with all the
requirements of the Rules of Court against forum-shopping; (il) to represent me
in any and all such legal actions and proceedings as well as in any related
appellate or review proceedings in higher courts or administrative agencies; (iv)
to sign verifications and certifications of non-forum shopping as may be
necessary in conjunction with the filing and prosecution of any case involving
the Company or any of its partners, officers, members, representatives and
employees; and (v) to consider the issues, the necessity or desirability of
amending pleadings, the possibility of obtaining stipulations or admissions of
facts and documents to avoid necessary proof, the limitation of the number of
witnesses, the advisability of a preliminary reference of issues to a commissioner,
entering into amicable settlements and compromise agreements, and such other
matters as may aid in the prompt disposition of any case involving the Company
or any ofits partners, officers, members, representatives and employees.
also appoint the said law firm of Nicolas & De Vega Law Offices as my
agent or representative upon whom I may be served notices or processes relating
toany case involving the Company or any of its partners, officers, members,
representatives and employees.
| further give and grant to my attorneys-in-fact full powers and authority
to do and perform all and every act requisite or necessary to carry into effect the
foregoing powers, as fully to all intents and purposes as I might or could
lawfully do if personally present, with full power of substitution and revocation,
and hereby ratify and confirm all that my said attorneys-in-fact shall lawfully do
or cause to be done by virtue hereof.
en ee nee Fees onen) ACKNOWLEDGMENT
REPUBLIC OF THE PHILIPPINES)
CITY OF MANDALUYONG )Ss.
Icertify that on this date before me, a notary public duly authorized in the
city above to take acknowledgments, personally appeared:
Name Driver's License No. Date/Place Issued
MATILDE HAYNES AO1-92-038451 09 May 2008/ DLRC
Robinson’s Galleria
who was identified by me through competent evidence of identity to be the same
person described in the foregoing instrument and who acknowledged before me
that her signature on the instrument was voluntarily affixed by her for the
purposes stated therein, and who declared to me that she has executed the
instrument as her free and voluntary act and deed; and who avowed, under
penalty of law, to the whole truth of the contents of the instrument.
WITNESS my hand and seal this 16° day of October 2009.
realdidtieao 5 e00l4s
FMANDALUY GHG CIT
5.0277 WIL OEG Sh. 2009
253: [/5/GS KADALOYORG CH Y
PIR
ISP 765880! / 28/08: PASIG CITY
ROLL QFATIORNEYS NO. 5176S LTD.
‘MANILA EXPLO!
PARTNER'S RESOLUTION
WHEREAS, MANILA EXPLORATION CO. - ANNEX LTD. INC (the
“PARTNERSHIP) is a partnership duly organized and existing under Philippine
laws
WHEREAS, the PARTNERSHIP desires to pursue legal action against
TONY HORN for Qualified Theft. damages, attorney's fees, and alll other costs
which incurred pursuant thereto, and to prosecute and defend all actions, both
civil and criminal, that may be filed against him;
NOW, THEREFORE, for and in consideration of the foregoing premises,
the majority of the Partners of the PARTNERSHIP hereby approves the following
resolutions:
“RESOLVED, that the Partners have authorized the filing of
@ criminal complaint for Qualified Theft under Article 310 of the
Revised Penal Code and other appropriate civil/criminal actions
and cases against TONY HORN as well as to enter, initiate or
participate in any ancillary proceedings, appeals, and appellate
court reviews in respect of, or arising from, the criminal cases or
other acts and transactions related thereto.”
“RESOLVED FURTHER, that the Partners have authorized
Ms. Leah Del Rosario Mayamaya cr any person or representative
authorized in writing by the PARTNERSHIP, (i) to represent the
PARTNERSHIP in the proceedings in any criminal cases that may
be filed in its behalf and to further represent the PARTNERSHIP in
any pre-trial, mediation or preliminary conference and other
proceedings in connection with the above-mentioned criminal case,
and all other cases, both civil and criminal that may hereafter be
filed, with full power to bind the PARTNERSHIP, at the pre-trial,
mediation or preliminary conference and such other proceedings;
(i) to sign, verify and file any and all pleadings or motions in
connection with the Case, and all other cases, both civil and
criminal that may hereafter be filed, to comply in behalf of the
PARTNERSHIP, with all the requirements of the Rules of Court
against forum-shopping; (iii) to represent the PARTNERSHIP in
any and all such legal actions and proceedings as well as in any
related appellate or review proceedings in higher courts or
administrative agencies; (iv) to sign verifications and certifications
of non-forum shopping as may be necessary in conjunction with
the filing and prosecution of the above criminal case, and all other
cases, both civil and criminal that may hereafter be filed; (v) to
consider the issues, the necessity or desirability of amending
pleadings, the possibility of obtaining stipulations or admissions of
facts and documents to avoid unnecessary proof, the limitation of
the number of witnesses, the advisability of a preliminary reference
of issues to a commissioner, entering into amicable settlements and verify, execute and deliver documents, certifications, powers of
attorney and other papers in connection with the foregoing
incidents and with full authority to bind the PARTNERSHIP”
“RESOLVED FINALLY, that the Partners also authorize the
law firm Nicolas & De Vega Law Offices, or any of its lawyers, to
appear for and in behalf of the PARTNERSHIP in all Proceedings,
incidents, and stages of the Complaint, including any ancillary
Proceedings, appeals, and appellate court reviews in respect of, or
arising from, the criminal case/s or civil case/s or other related acts
and transactions, and any preliminary investigation, pre-trial or
continuation thereof, for purposes of which the PARTNERSHIP
grants them the authority to consider and agree to:
1) an amicable settlement of the case;
2) the referral of the case to mediation or other
forms of dispute resolution:
3) facts that need not be proven, either
because they are matters of judicial notice
or expressly or deemed admitted:
4) amendments to the pleadings;
5) the possibility of obtaining stipulations and
admissions of facts and documents;
©) objections to the admissibility of
testimonial, documentary, and other
evidence;
7) objections to the form or substance of any
affidavit, or part thereof;
8) the simplification of issues;
9) the possibility of submitting the case for
decision on the basis of position papers,
affidavits, documentary and real evidence;
10)availment of discovery procedures or
referral of the case to commissioners;
11) a complete schedule of hearing dates; and
12) to consider and agree to such other matters
as may aid in the speedy and summary
disposition of the case.”
APPROVED AND ADOPTED, this 15% day of October 2009 in
Mandaluyong Ci Manila, Philippi
“ee
MATILDE NORMAN HAYNES Pas
Partner ——— 4C OF THE PHILIPPINES :
a
SECURITIES AND EXCHANGE COMMISSION
ing, EDSA, Greschills
ecaluyoog, Mero Manila
COMPANY REG. NO. APO9S-00930
KNOW ALL PERSONS BY THESE PRESENTS:
‘THIS IS TO CERTIFY that the annexed
Amended Articles of Partnership
MANILA EXPLORATION CO. - ANNEX, LTD.
has been presented to the Commission at Yelock in the afternoon of the
26° day of January, 2007, according to Entry $441 of Volume XVIII of the
Day Book and duly recorded in Folio 66 Leaf No. 56448 Inscription No. G)
Volume TV of the Book of Partnership of the Securities and Echange
Commission.
IN TESTIMONY WHEREOF, I have hereunto set my hand and caused
the seal of this Commission to be affixed at Mandaluyong City, Metro Manila,
Philippines, this 4 day of February, Two Thousand Seven.
§ Registration and Monitoring Department REPUBLIC OF THE PHILIPPINES)
ANGELES CITY ss
AFFIDAVIT
L SHAYNE A. FAIRBANKS, Filipino, of legal age and with office address
at No. 35 - 8 Sarita St, Diamond Subdivision McArhur Highway, Brgy.
Balibago, Angeles City, Pampanga, after having been duly sworn in accordance
with law, do hereby depose and say:
1. Tam the personal secretary of Mr. Norman Haynes (” Mr. Haynes”)
one of the owners of Manila Exploration Co.-Annex, Ltd. ("MECO”) since 21 July
2006 to present. Our office address is located in No. 35 - 8 Sarita St, Diamond
Subdivision, McArhur Highway, Brgy. Balibago, Angeles City, Pampanga
(‘Office Address”). We are engaged in the conduct of exploratory drilling,
electronic prospecting and excavation research.
2. also personally know Mr. Tony Brian Hom (“Mr. Hom”). He was
a former contractual consultant and part of the Managerial Staff of MECO. Mr.
Horn also represented himself as an evangelical minister/pastor for a certain
small church group based in Angeles City.
= Since he presented himself as a church minister, I observed that
great trust and confidence was given by Mr. Haynes to Mr. Horn in the discharge
of his duties and responsibilities. On most occasions, Mr. Haynes rarely monitors
his work, unlike most rank and file employees where observance and strict
compliance with company policies are expected.
4. Such was the trust and confidence reposed on Mr. Hom, that when
Mr. Haynes was on sick leave, the administrative functions of payroll and hiring
of personnel were temporarily entrusted under the management of Mr. Hom.
5. One of the office policies which both the Management and
employees strictly observe is the confidentiality of office files documents and
records both in printed form and those contained in the computer main frame.
Thus, I keep all the sensitive files in a cabinet beside my table. Only Mr. Haynes
and I are allowed access to the cabinet and its contents.
6 That on one occasion, I saw Mr. Horn browsing and taking those
files out from my cabinet without my permission. That upon verification, after I
saw Mr. Horn taking files out of my drawer, I discovered that the following
documents such as the Company's Securities and Exchange Commission
Registration, Official Receipt and Certificate of Registration of the Company's
motor vehicles, land titles as well as other pertinent documents were missing
from my drawer. Since Mr. Horn is also my superior, I secretly mentioned to Mr.
Haynes that he took certain files from the cabinet without his consent. Thus, Mr.
Haynes instructed me to keep a close eye on Mr. Horn.
7. Further, one of my duties as Mr. Hayne’s personal secretary is to
keep and maintain all pertinent and highly confidential files of MECO such as & That I personally know Mr. Neal Cortez (“Mr. Cortez"), who was
hired by Mr. Horn to be his assistant Mr. Cortez was known to have
extensive knowledge in computers.
9. That the Company maintains a computer system accessible only by
Mr. Haynes and with his consent The aforementioned computer unit maintains
the mainframe system of the Company, the lists of personnel. client and investor
profiles, pertinent documents, forms 2s well as the payroll system of the
10, That on several occasions I saw Mr. Cortez with Mr. Horn copying
lent and investor files from the Company's computer, without the consent of
Mr. Haynes nor any proper officers of MECO.
11, _ Further, 1am likewise tasked to inventory the equipments issued to
the employees. Per count, a desktop computer and two (2) units of laptop
owned by MECO are missing and remained unaccounted for, after the departure
of Mr. Hom from the company. Subsequently, the MECO management
informed us that Mr. Hom’'s absence was due to his decision to terminate his
services with MECO.
12 Lexecute this Affidavit to attest to the truth of the foregoing. to
that handed confide fil id to Mr. Hor
of which no return was ie, likewise the MECO owned desktop and two (2)
laptop computers remains missing and unaccounted for. I execute this Affidavit
also in support of the Company's action against Mr. Horn and Mr. Cortez for
qualified theft, and for whatever legal purposes it may serve.
FURTHER, AFFIANT SAYETH NAUGHT.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 16th
day of October 2009 at Angeles City.
SHAYNE A. FAIRBANKS
Affiant
This is to certify that I have persdrdihy
Complaint-Affidavit; that 1 am satisfied fhat th
and that she executed the same of her own f ae Tee
REPUBLIC OF THE PHILIPPINES)
ANGELES CITY )ss.
AFFIDAVIT
I JONATHAN B. CRUZ, Filipino, of legal age and with office address at
No. 35 ~ 8 Sarita St, Diamond Subdivision. McArhur Highway, Brgy. Balibago,
- Angeles City, Pampanga, after having been duly sworn in accordance with law,
do hereby depose and say:
1, Tam a security guard of Manila Exploration Co.-Annex, Ltd.
(“MECO”) since 04 January 2005 to present.
2. That I personally know the owner of MECO, Mr. Norman Haynes
(Mr. Haynes”). Likewise, I personally know that Mr. Tony Brian Horn (“Mr.
Horn’) was a former contractual consultant and a part of the Managerial Staff of
MECO.
3. Sometime in October 2008, when I was the guard on duty, I
personally opened the rear gate of MECO compound for Mr. Horn because he
said that he wanted to get his personal things from the office. I did not ask any
clarificatory questions at that time, since he was regarded as a “boss” in MECO,
the company I was working for.
4. Tomy surprise, Isaw him hastily loading computer units and some
bulky folders with MECO logo inscribed on them in his car. Thereafter, he
immediately left MECO's premises without a word. Iwas afraid to confront Mr.
Horn about why he took the company’s property because he is my superior.
5. Suchincident was given clarity when I was informed that Mr. Horn
resigned from MECO and it was then discovered that the important MECO
owned computers and files were missing. Thereafter, I mentioned to Mr. and
Mars. Haynes about the incident that Mr. Horn took some of MECO’s files and
computers.
6. Lexecute this Affidavit to attest to the truth of the foregoing, to
Horn I MECO-owned com units and into
his car. I execute this Affidavit also in support of MECO’s action against Mr.
Horn for qualified theft, and for whatever legal purposes it may serve.
FURTHER, AFFIANT SAYETH NAUGHT.
IN WITNESS WHEREOF, I have hereunto affixed my signature this 14th
<< B.CRUZ
day of October 2009 at Angeles City. This is to certify that I have
Complaint-Affidavit; that I am satisfied that
and that she executed the same of her own fre
«at the City Prosecutor
angeles City h
yor: 220
March 16, 2009
MR. TONY B. HORN
uit Plaza Clara M. Recto Hithway
Pampanga. PRIiADINeS alle A Resi
ho (6346) 499.1199
No (8) $99.1200
i “ 3 Ww
tal ail i 4 RET TREE CNEX .
Lai
wyer/ Realtor
c/o Trinity Baptist Church
Brgy. Sapang Bayabas
Dau, Mabalacat, Pampang@
Dear Mr. Horn:
My client, OPSEC INTERNATIONAL
appropriate legal action your accountability a
FOUR HUNDRED. THIRTY NINE PESOS AND
representing the amount of company funds unaccoun
to October 2008.
In addition to this amoun!
documents/items:
GROUP INC. (OPSEC, for brevity
mounting to PESOS: NINETY THOUSAND
iL The FMC Walloway
seia camer Calle BROS
has referred to me for
FIVE CENTAVOS (90,439.75)
ted for the auditing period of Januery
te reports showed thet during your employment with OPSEC, you
fave taken without authority and to the damage of the company, the following
+. Accomplished Contract of Employment for all OPSEC employees:
Register for the Period of May 2007 to October 2008;
2. Payroll
3. Database
¢ Files for all OPSEC employ
4. Allother communications files
ees; and
Likewise, thas also come to the attention of my client that "STE of your separation from
OPSEC, you have been unofficially communicating
employees and investors with the evident ine
goodwill of OPSEC toits s
erious
negative information to my client’
of undermining the reputation an
damage and prejudice.
cto woid any legal complication, demand is hereby made Pee you, to cease and desis
effective immediately upon your receipt hereof,
activity or communication
investors, which tends to
n with my client:
from engaging !n any destabilizattc
's present and previous employees, as well as j
heeaten the stability of my clients good standing,
pemand is also made upon you to pay in full the amount of P90,439.75, plus &
aernatsentioned items, within SEVENTY TWO (72) hours days from receipt of this lett
Stherwise, to protect my client's inverests, f will De cont
cases against you.
to file CRIMINAL and CLV i
.
nd lawful demand, we will not hesitate to file
Should you fail to accede to this legitimate a
costs of suitand attorney's fees.
the appropriate cases against you, with claim for camages,
Please be guided accordingly. Republika ng Pilipinas )
LALAWIGANNG PAMPANGA SS.
LUNGSOD NG SANFERNANDO )
SINUMPAANG SALAYSAY
AKO. LEAH C. DEL ROSARIO-MAYAMAYA 30 tao:
asawa at kasalukuyang nakatira sa No. 35-8 Sarita St, Dia
Brey. Balibago, Angeles City, Pampanga, matapos na makepanum;
nagayon sa Bates ay Malaya at kusang loob na nagsasalysay ng gaya
sumusunod:
NA, simula pa ng mga nakareang taon Abril 2007 at 2008 ay unti unti
ng nawala ang mga gamit namin sa aming opisina sa MECO na matatagpuan
sa Brgy. Balibago, Angeles City, tulad ng dalawang (2) unit ng Clone
Notebook Laptop with MECO DATA BASE/HARD DRIVES; Personal
Desktop Computer w/ MECO File Hard Drive: Records Herd Drives;
dalawang (2) piresong USB Memory Stick; assorted CDs/Diskettes; Stock:
Expenses and Financial Transactions Ledgers; Certificate of Partnership.
Records of Partnership Participation: Investors Data Base; Subsisting
Conwaets, and Other MECO/OPSEC Files at ito ay kinuha ng consultant ng
aming company na si TONY BRIAN HORN se hindi melamang dahilan
bage siya mag resign noong Disyembre 2008;
NA. nagpadala ang aming kumpanya ng demand letter para ibalik ni
YONY BRIAN HORN ang nasabing mga dokumento at mga computers at
data base ng MECO Company subalit ito ay binale wala lamang ni TONY
BRIAN HORN:
NA, makalipas halos isang (1) taon, mga alas 10:00 ng umaga
Setyembre 2009, ako ay nagpunta sa bahay ni TONY BRIAN HORN sa
Sapang Biabas, Dau, Mebalacat, Pampanga, upang siya ay kamustehin, at sa
hindi ineasahang pagkaketaon ay nakita ko sa kanyang bahay ang nasabing
mga gamit nang aming kumpanya kong’keya’t nekiusap ako na ibalik niya
ang nasabing mga gamit;
NA sa halip na ibalik ay tinakot pa ako ni TONY BRIAN HORN at
anyang sinigawan habang aking nakita ang isang bari! na pistola na naka
ikbit sa kanyang baywang at ibabalik lamang daw niya ang nasabi
gamit kung ito ay tutubusin ng MECO sa hindi nasabing halaga at
ay mayroong Cour Order,
NA. so aking takot ake ay umalis na lameng at humigit kumulang sa
ala 1:00 ng hapon ng araw ding iyon Setyembre 28, 2009, nagtungo ako sa
opisina ng Regional Special Operations Group sa Camp Olivas, Pampanga
para humingi ng tong 2 maibalik ang nasebing mga nalagane
dokumento at ang mga computers ng eming kumpanya at napag pasyehan na
aplavan ne Search Werrant ane bahay ni TONY BRIAN HORN perm NA. ginawa ko ang salaysay kong ito ng walang sino mang a
makot 0 nagbigay ng pabuya sa akin para gawin ito, bagkus ito ay Kus 22
sarili Kong kagustuhan:
ture,
NA BILANG PATOTOO sa lahat ng ito ako ay kusang loob na
eda ng aking pangalan sa ibaba nito ngayong ike-28 ng Setyembre 2009
to sa Camp Olivas. San Femando City, Pampanga.
LEAH C. DE!
(Nagsalaysay)
MAYAMAYA
“ILAGDAAN AT PINANUMPAAN sa harap ko neayong ika-28 ng
imbre 2009 dito sa San Fernando City, Pampanga. -
Administering Officer LR Ana
SPECIAL POWER OF ATTORNEY
KNOW ALL MEN BYTHESE PRESENTS:
Haynes of legal age,
2, Balibago,
anc eppoint Leah Mayamaya, of legal age
1a Cecilia Subdivision, Guitnang Bayan I. So, Matvo, Rizal to be my les
lawful representative and signatory to sign, transact and coordinate on
regard to the matters Pertaining to the search “errant application for the recovery of ail
the files and investor database, office instruments like Office files, 2 pieces clone
notebook laptop, 1 clone Persona] Computer Desktop, MECO database, 2 pieces USB
sticks, CDs and diskettes, stacks of Papets documents, financial transactions and
subsisting contracts and records of partnership participation belonging to MANILA
EXPLORATION CO, it’s stockholders and other agent companies that is taken
out without our consent and now under the Possession of Tony Brian Horn in his house
at Sepang Biabes, Mabalacat Pampanga.
HEREBY GIVING AND GRANTING unto said Attorney-in-fact full power
and authority to perform all act and thing which may be necessary to cany into effect
the foregoing authority as fully to al] intents and Purposes as I might lawfully do as if
personally present unto my said ATTORNEY-IN-FACT shall lawfully do as if Personally
Present unto my said presents:
This authority shall inchude the ae paaie Cbtain a search warrant ageinst
pony Brian Hom sign Complaint form oF Position Papers, Supplemental
Position Paper, Reply, Compromise Agreement, Notice of Appeal and
Memorandum of Appeal and all kinds of pertinent pleadings relative to the case
including the power to enter into an amicable settlement with the Complainant
"and attend hearings for the said case=
IN WITNESS WHEREOF , I have hereunto set my hand this 29% day of
September,2009 in Ortigas City, Philippines.
RHA AMAYA,
PARTNER ATTO! IN-FACT
Driver License No, AO1-038451 CIC No. 13166638
Issued on 05-09-2008 Issued on 01-08-2009
Issued at Quezon City Issued at San Mateo Rizal
x oT
NORMAN DEAN Hayy
LIMITED: PARTNER:
PASSPORT NO.057131065
Issued at San Francisco
Issued on 03-10-2003
SIGNED IN THE PRESENCE 0} ACKNOWLEDGEMENT
REPUBLIC OF THE PHILIPPINES )
CURIOS CY a 5 )ss
BEFORE ME, a Notary Public for and in QUAM Aly, this are day of September 2009
personally appeared his Driver License No. A01-038451 on May 09, 2008 at Quezon City of
Matilde Haynes and Passport No. 067131065 at San Francisco on March 03.2003 of Norman
Haynes.
Known to me and to me known to be the same persons who executed the foregoing
truments and whe acknowledged to me that the same is their free and voluntary act and deed
and/or that of the minor they represent. £
IN WITNESS WHEREOF, I have hereunto set my hand seal on the date and place above
written.
NOTARY PUBLIC
UNTHL DECEMBER 31. 2010
PTR NO. 1174049, 31/97/09 MLA,
IEP NO. 758239 0105/09. HLA.
ROLL NO” 26555/TIN & 16+51S-386
ICLE COMPLIANCE NO. 1100Ise72 DoT se mur rvs NA SIONAL POLE
REGIONAL MOBILE GROUP.
Regional Special Operations Group
Camp Olivas. City of San Fernando, Pampanga
i ANT NO_
For: Violation of Art. 310 of the
RPC (Qualified Theft).
sal or Occupants of the honse in
Biabas. Dau, Mabalacat.
APPLICATION OF SEARCH WARRANT
COMES NOW, the undersigned PINSP NORBERTO § MURILLO,
of the Regional Special Opertions Group, Police Regional ¢
ue National Police (PNP), Camp Olivas, City of
Pampanga. respectfully request a Search Warrant to
oudent wath address at Sapang Biabas, Dau, Pamp:
bed anc wlustrated in the sketch and photograph h
Amuexes “A” and ~B", respectively. for the purp:
following it
jan Femande.
© above-named
more pan icularly
erete attach
pose of seizin
cumenis owned by MECO/OPSEC COMPANY
ithe
a Two (2) units Clone Notebook Laptop with MECO
DATA BASE/HARD DRIVES;
Ss:
Personal Desktop Computer w! MECC File Hard Dnve:
Records Hard Drives:
‘xpenses and Financial Transactions L
Cenificate of Parnership;
Records of Partnership Participation:
Investors Data Base: -
Subsisting Contracts; and
Other MECO/OPSEC Files.
All of the foregoing articles/items used or intended to be used
ay spondent in viclating the Article 310 of the RPC ~Qualified
Theft" are hidden and kept. at the above-stated address.
= 1 was int
pondent is Keeping in ius possession and conucl the
at tas house located in S: j yw somennie on the month of
¢ HORN. consultant of the }
cok and cutte.
documents without the Kuowieds
the MECOOPSEC COMPANY
rif ingudented ems
ese ntanve
ou Septenber 28, 2009, at around |
presentative of the MECG
yamaya went to dhe licuse of MR.
1} totier, surprisingly savv all the inporan: ce
i | 4 to MECO;OPSEC COMPANY Airs
\4
te il 5 Vha i wes uutermed
JORN 15
vera focal Zovertume
aux Pwapanga. Hence. in order to minimize the possibility of
d to epsure the effective service thereet.
sed applicant is coustrained to apply the iustan{ applicati
this Honorable Court, From my previous experience it as pera
siden: (6 apply for a search warrant in a differen: judiciat
eli from tie lecation of subject establishment.
as
2 Cyon the facie above-stated. | have cause 10 beheve ant veal
that che premnses of the sbove-named respordent found
sisi Addvess the Violations uf Article 310 of the Revised 1
aiivied Theft.
aleectin
Rove for ¢
signee, 98 the Sain
4 iv the sirnival ad civ} actions WI
eedless wo State. the
ro the control and directic
pica respectfully undert
J) mn the reasonable opportaruty and
snorabic Court
juve verified al matiers relevant to the uivests
d-sementioned oflense dlegedly perpeirated by the Tes: otideat ait
x he trie anid con ect and therefore have reason tha: search &
aseach vt
Be es Saree Blas City of San Femando, Pampanga, _Oet0g \ 2009
TO $ MURILLO
Applicant :
SUBSCRIBED AND SWORN to before me this 1ST day of
Ose. 2009 at San Femando City, Pampanga.
CONRADO B QUILALA JR.
Police Senior Inspector
Chief, RSOG
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