REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
MAKATI CITY

ABC CORPORATION,
Complainant/s,

NPS Docket No. XV-05-INV-19H-

-versus- 1100
For: QUALIFIED THEFT under
Article 310 of the RPC
W, X, Y and Z.,
Respondent.

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

COUNTER – AFFIDAVIT

I, W, Filipino, of legal age, married, with residential address

at Unit 2202, 6768 Ayala Avenue, Corner Paseo de Roxas, Makati City
1200, is a Warehouse Manager of the Corporation, after being duly sworn
in accordance with law, do hereby depose and state the following:

1. That I am the respondent in the instant complaint;

2. At the onset, I vehemently deny and brand as malicious,

baseless, unfounded and unjust fabrications that the
instant complaint has leveled against me;

3. The truth of the matter are as follows:

A. As to the allegations contained in paragraph 5, 9,
and 22 of the Complaint-Affidavit I admit the same,
only as to the nature of my work and my position as
an employee of ABC Corporation. As to paragraph
30, I admit submission of my resignation letter.

B. However as to paragraphs 23, 30 and 31, I am

denying the same for absence of personal knowledge
as to the occurrence of the said events;

C. The allegations contained in paragraphs 10, 15, 16,

17, 18, and 19, I am denying the same for lack of
personal knowledge as to said events.

D. In paragraphs 11, 12 and 13, I deny the same, I don’t

have the locks for the first and second. The
warehouse has no exact time as to the opening.

E. In paragraphs 14, 20, 25, 26, and 27is merely an

opinion of an ordinary witness and no relevant
evidence to justify a conclusion.

F. While I have been granted access to the warehouse,

this is not exclusive as alleged in paragraph 21.

G. I don’t have personal knowledge as conversation of

Security Guard and the person who alleged the
private disclosure in paragraph 24

H. In paragraphs 28 and 29, there is impossibility as to

the procedure in counting the alleged missing

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 inventories. I cannot count on something which is
alleged to be missing. Hence the denial.

PRAYER
WHEREFORE, premises considered, it is respectfully prayed
that the instant criminal complaint be DISMISSED for lack of merit.
FURTHER, the respondents respectfully pray for such and
other reliefs as may be deemed just and equitable in the premises.

IN WITNESS WHEREOF, I have hereunto affixed my

signature this 22nd day of August 2019, in
Makati City, Metro Manila .

W
Defendant

SUBSCRIBED AND SWORN TO before me this 22nd day of

August 2019, in Makati City, Metro Manila .

CERTIFICATION

I HEREBY CERTIFY THAT I have personally examined the

affiant and I am satisfied that he voluntarily executed and
understood his own affidavit.

BBB
ASSISTANT CITY PROSECUTOR

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