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Republic of the Philippines

Depart of Justice
OFFICE OF THE CITY PROSECUTOR
Lapu-lapu City

KARL H. DRABER,
Complainant,
I.S. NO.___________________
-versus- For: QUALIFIED THEFT
)
NEILDA LONGAKIT TORION,
Respondent,
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LETTER-COMPLAINT

December 11, 2017

THE CITY PROSECUTOR


Hall of Justice, Lapu-lapu City

GREETINGS:

I respectfully file a formal complaint against one Neilda


Longakit Torion for the crime of Theft. The respondent may
be served with subpoena and other processes of this
Honorable Court at the following address:

Neilda Longakit Torion


Owak, Asturias, Cebu

The facts and circumstances surrounding the


commission of the crime are narrated in the attached
Complaint-Affidavit together with the documentary annexes.

I respectfully request that after the preliminary


investigation, should the evidences warrant, appropriate
criminal information be filed in Court.

Very truly yours,

Assisted by: KARL DRABER


Complainant

ATTY. MARIO S. RIZON, JR.


Counsel for the Complainant
CORTES and RIZON Law Office, M. Rizon Bldg., Sebastien Hotel,
ML Quezon Highway, Ibapo, Mactan, Lapu-lapu City 6015, Phils.
Tel # 0324951077; email: mariojr85@gmail.com
IBP No. 5619; May 18, 2017; Cebu Prov.
PTR NO. 6592191; July 3, 2017; Lapu-lapu City
MCLE COMPLIANCE NO. (newly admitted to the bar)
Roll of Attorneys No. 67543

REPUBLIC OF THE PHILIPPINES )


CITY OF LAPU-LAPU ) S.S.

COMPLAINT-AFFIDAVIT

I, Karl Draber, of legal age, Austraian Citizen, single,


resident of Eloisa Royale Suites, Maximo V. Patalinghug Jr.
Ave., Lapu-Lapu City, Cebu 6015 Philippines, after having
been sworn to in accordance with law, do hereby depose and
say:

1. That I personally know Neilda Torion because we


were together for more than twelve months, since she was
my fiancée.

2. That on May 20, 2017, Neilda and I were staying at


the Eloisa Royal Suites, and after placing our luggage into
our room, we rested for thirty (30) minutes, and it was
during that time that I put one of my wallets containing Php
120,000 into the safe box located at the room.

3. That the aforesaid safety deposit box has a code,


and I shared the aforementioned code, knowing that she
could be trusted since she was my fiancée and the fact that
she is the only person that can help me, in case of
emergency.

4. That before the crime of qualified theft is committed,

4. That despite the given trust and confidence, the


accused did then and there willfully, unlawfully, and
feloniously by means of stealth and surreptitious act,
committed a crime of qualified theft against the undersigned
by pretending
5. On August 4, 2010 while I was about to check in with
KLM for the 10:45 A.M. flight KL 0804 at the Ninoy Aquino
International Airport I was dismayed and felt humiliated
because I and my son KARL were denied boarding for reason
that our KLM electronic round trip tickets were unpaid.

6. I immediately called Ms. Leonado but the latter failed


to give our valid airline tickets. Left with no other option
considering that my husband was waiting for our arrival in
Norway, I purchased from Time Travel & Tours, Inc. another
two tickets via Singapore Airlines along a different route from
Manila –Singapore-Copenhagen and paid U$ 2,580 dollars.
At Copenhagen, I purchased again another Airline tickets for
two via Scandinavian Airlines for the route Copenhagen-
Stavanger and paid DKK 6,068 Danish Krone. The total cost
of the tickets which were paid in U$ dollars and Danish Krone
is equivalent to One Hundred Sixty One Thousand Six
Hundred Forty Six (Php 161,646.00) at 43.50 pesos to a
dollar and 5.34 Danish Krone to a dollar prevailing exchange
rates.

A copy of the Official Receipt from Time Travel and


Tours, Inc for the purchase of Singapore Airline Tickets is
hereto as Annex “D”. The Singapore Airlines E-Ticket is
hereto attached as Annex “E” and the Scandinavian Airlines
Ticket as Annex “F”.

7. That MS. CHERUBY LEONADO as the Branch Manager


of the travel agency (Smartway Travel and Tours Services)
misappropriated the money that I paid to her to purchase
KLM round trip tickets. Worst, she presented and gave me
round trip tickets which were results of imaginary purchase
transactions with KLM. All along I was made to believe that
the round trip tickets were valid as there was no problem
when presented to the Norwegian Embassy for the release of
our VISA.

8. Our denial from boarding KLM Flight 0804 caused us


great inconvenience, dismay and embarrassment at the KLM
check-in counter of the Ninoy Aquino International Airport,
and constrained me to purchase on the spot another tickets
for me and my son at a higher price in the amount
equivalent to 161,646.00 pesos with Singapore Airlines and
Scandinavian Airlines to my damage and prejudice.

9. That despite repeated demands Ms. Leonado failed


and still fails to return the amount she misappropriated.
10. That I am executing this affidavit in order to support
a criminal complaint for estafa against the said MS.
CHERUBY LEONADO pursuant to the pertinent provisions of
Article 315 of the Revised Penal Code.

IN WITNESS WHEREOF, I have hereunto set my hand


this ___ day of October, 2010, at Lapu-lapu City.

MARILOU BECKSTROM
Affiant

SUBSCRIBED AND SWORN TO BEFORE ME this ___ day


of October, 2010, at Lapu-lapu City.

I hereby certify that I have personally examined the


affiant and I am fully satisfied that she voluntarily executed
and fully understand the contents of her affidavit.

PUBLIC PROSECUTOR.

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