REPUBLIC OF THE PHILIPPINES )

DONE: IN THE CITY OF BAGUIO) S.S.

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COMPLAINT-AFFIDAVIT
ILLEGAL RECRUITMENT

I, Juan Dela Cruz, Filipino, of legal age, single and presently residing at Lower
Pinget, Baguio City, Philippines, after having been sworned in accordance with law do
hereby depose and say:

1. That I vehemently DENY flatly and categorically all the malicious, baseless,
malevolent, and trump up charges being thrown against me, that I respondent did not in
one way or another as a way of practice involve myself and my prestigious name in the
business of committing illegal recruitment and Estafa whether as an agent or general
manager;

2. That I, respondent is a bonafide businessman engaged in the business of event

planning with business name Party Pop located at 4 th Floor Annex Bldg. Porta Vaga Mall
Session Road, Baguio City.

3. That on March 17, 2015, I met Isabel Valdez together with Lourdes Campos and
Pedro Delos Santos at my place of business located at 4th Floor Annex Bldg. Porta Vaga
Mall Session Road, Baguio City.

4. That said Isabel Valdez and companions passed by to inquire regarding my event
planning services, that while in my place of business , I overheard them conversing about
wanting to leave for abroad and their need for an agency to help them with their papers.

5. That I interferred and told them about the Integrated Manpower Agency located
across the street at 5F PhilAm Bldg., Upper Session Road, Baguio City.

6. That on March 19, 2015, they returned to confirm their intention to avail my
services for party package A worth One Hundred Thousand Pesos (Php 100,000.00) and
paid the corresponding amount in check numbered 123

7. That the check was issued in the name of Juan Dela Cruz/Party Pop by Isabel
Valdez as full payment for my services

8. That as evidence of the amount received in check, I issued a receipt numbered

1200111 but subsequently gave two more receipts as per request of Lourdes Campos and
Pedro Delos Santos

9. That the additional receipt issued as proof of their contribution of the above
mentioned amount however it was issued in blank bearing only my name
 10. That the said receipt was filled up by them and made to appear to have been
issued by Integrated Manpower Agency located at T9 3rd floor, Centermall Bldg.,

11. That the said agency located at T9 3 rd flr, Centermall Bldg., was declared to be as
an unlicensed recruitment agency by the certification of the Department of Labor and
Employment attached as Annex D and E in the complaint,

12. That there exist two Integreted Manpower Agency, one located at T9 3rd floor,
Centermall Bldg., Baguio City which is unlicensed and one located at 5F PhilAm Bldg.,
Upper Session Road, Baguio City which is a licensed recruitment agency as certified by
Annex.

13. That I am in no way related to both agencies as an agent nor as a general manager

14. That I am voluntarily executing this affidavit to attest to the truthfulness of the
foregoing facts and to support the outright dismissal of the complaint filed against me.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 26th day of February
2016 at Baguio City, Philippines.

JUAN DELA CRUZ

Affiant

SUBSCRIBED AND SWORN TO before me this 26th day of February 2016 in the City
of Baguio, Philippines and I further certify that I have personally examined the affiant
and I convinced and satisfiedthat he voluntarily executed the foregoing Counter Affidavit
and understood all the contents hereof and that they are true and correct as to his own
personal knowledge.

1. Juan Dela Cruz offered and promised that we will work as nurses in a certain
Sanad Hospital, Riyadh City, Saudi Arabia and earn a salary ranging from 50,000.00 to
100,000.00 monthly and that he will help us obtain working visas and passports.

3. On March 19, 2015, convinced by the respondent, each of us paid the amount of
P100,000 for our travel documents through his agency, Integrated Manpower Services
and to secure our working visas, Philippine Passports and among others, which are to be
processed in the DFA and Saudi Arabia Embassy. A copy of the official receipts issued to
us is hereto attached as Annex B.

4. We likewise submitted documentary requirements to the agency on the said date. A

copy of the documents copy furnished by the agency is hereto attached as Annex C.

5. After payment, completion and submission of the necessary documents,

respondent told us that our flights were already booked.

6. After a month of waiting, there was no development and we did not receive any
information or notice of our applications.

7. Moreover, Juan Dela Cruz was not in his office anymore.

8. This prompted us to validate and inquire from the Philippine Overseas
Employment Agency (POEA) regarding the matter and the said agency informed us that
Integrated Manpower was not a registered recruitment agency. A copy of the certification
from the POEA is hereto attached as Annex D.

9. Moreover, Juan Dela Cruz was likewise not licensed nor authorized to recruit. A
copy of the certification from the POEA is hereto attached as Annex E.

IN WITNESS WHEREOF, we have set our hands this 10th day of February 2016 in the
City of Baguio.