Republic of the Philippines
Department of Justice
PROVINCIAL PROSECUTION OFFICE
Daet, Camarines Norte
__________________________,
Complainant, NPS DOCKET NO: ____________________________
For: Violation of Section 3 (e) of RA 3019
Otherwise Known as “ANTI-GRAFT AND
CORRUPT PRACTICES ACT”
____________________________
Respondents,
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COMPLAINT
COMES NOW, the undersigned complainant of the above entitled case under oath, accuses
___________________________ of Block 3, Lot 28, Holiday Homes, Brgy. Lag-on,, manager of
___________________________, Ground Floor Central Plaza Mall, Barangay Lag-on,
Daet, Camarines Norte for the crime of Violation of Section 3 (e) of RA 3019 Otherwise
Known as “ANTI-GRAFT AND CORRUPT PRACTICES ACT”, committed as follows;
That on September 21, 2018 and for sometime prior or subsequent thereto at the
Municipality of Daet, Camarines Norte, the above-named accused _________________, a public
officer, being the Public School District Supervisor of DepEd Mercedes District, in such capacity
and committing the offense by taking advantage of her official function, with evident bad faith,
conspiring with _____________, a bank manager of ______________, did then and there,
willfully, unlawfully, and criminally cause undue injury to private complainant
__________________ through a combination or series of overt criminal acts, as follows:
a. By then and there forcing ___________ to part with his money amounting to
Php550,000.00 through the accused’s exercise of moral ascendancy as supervisor over
the complainant and directing him to apply for loan at the _____________ Bank for said
amount;
b. By facilitating the application and immediate approval of the loan from the
_____________ Bank and acting in conspiracy with the latter’s bank manager
____________________ where the proceed was collected by ___________________;
c. By intentionally not returning the large portion of aforesaid money she obtained from the
complainant amounting to Php448,735.82, thus, exhibiting bad faith and causing undue
injury to the complainant.
CONTRARY TO LAW
_________________
Complainant