Republic of the Philippines)

City of Davao ) s.s.

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COMPLAINT

The UNDERSIGNED, RAMON KHALIL C. ERUM IV, accuses JASON

Y. MOMOA, of Theft, defined and penalized by Article 308 of the Revised
Penal Code, committed as follows, to wit:

That on February 14, 2019 at about 11:30 in the evening in the City of
Davao, Philippines, the above named accused, JASON Y. MOMOA did then
and there willfully, unlawfully, feloniously, take, steal and carry away Php
500,000 from the vault located in the house of the undersigned, located at
No.123 fairview street, Ladislawa Village, Buhangin, Davao City owned by
the undersigned, thus performing all the acts of execution which would
produce the crime of theft.

The undersigned executed this affidavit to attest the truthfulness of the

foregoing facts and to support the filing of Criminal Cases against JASON
MOMOA for violations of Article 308 of the Revised Penal Code.

11:00 am , this 20th day of February, 2019.

__________________
Offended Party

SUBSCRIBED AND SWORN to before me this 20th day of February at

Davao City. I HEREBY CERTIFY that I have personally examined the
herein offended party and I am satisfied that they voluntarily executed and
understood their given affidavit.

Notary Public
Doc. No. ______;
Page No. ______;
Book No. ______;
Series of ______;
Republic of the Philippines)
City of Davao ) s.s.
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COMPLAINT AFFIDAVIT

I, RAMON KHALIL C. ERUM IV, of legal age, Filipino and a resident of

No. 123 Fairview street, Ladislawa Village, Buhangin, Davao City, after
having been sworn to in accordance with law hereby depose and state:

1. That I am accusing Mr. JASON Y. MOMOA a resident of Isla Suerte,

Brgy Bucana, Davao City, of theft.

2. JASON Y. MOMOA is my personal driver and bodyguard;

3. At around 8:00 am on February 14, 2019 when I checked my vault in

my room, I realized that the cash bundle of Php 1,000 pesos worth
Php 500,000 was missing;

4. Upon checking the CCTV camera installed in my room, I saw JASON

Y. MOMOA opened the vault and took away the cash bundle;

5. When I confronted JASON on the whereabouts of the cash bundle he

stole, he denied such allegations and immediately ran away from the
premises of my house.

SUBSCRIBED AND SWORN to before me this 20th day of February at

Davao City. I HEREBY CERTIFY that I have personally examined the
herein offended party and I am satisfied that they voluntarily executed and
understood their given affidavit.

Notary Public
Doc. No. ______;
Page No. ______;
Book No. ______;
Series of ______;
 PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court that judgement be rendered in favor of the plaintiff

Such other reliefs and remedies under the premises are likewise prayed
for.

Davao City, Philippines, this 15th day of February 2019.

_________________________________
Counsel for the Plaintiff
PTR No. 185045569:1-04-19:B.C.
IBP No, 6663344:1-04-19:B.C.
Roll No. 56905:5-15-16: Davao
Rm. 11-12 City Triangle
C.M. Recto, Davao City