Arrianne Aringo Direct Examination

Purpose:

1. The position of accused Magat and Reyes at TL;

2. The location of the scrap metal and keys inside TL;

3. That accused Magat and Reyes have access to the scrap metal and keys;

4. That accused Magat and Reyes position's at TL enabled and facilitated them
to take the scrap metal and keys;

5. ID and authenticate relevant documents.

Preliminary

Q: Good morning, Ms. Witness.

A: Good morning.

Q: Are you familiar with the case?

A: Yes.

Q: Why are you familiar with the case?

A: I filed the Complaint for Qualified Theft against the accused Manuel Magat
and Robert Reyes.

Q: Do you know the accused?

A: Yes.

Q: Why do you know the accused?

A: Because I am the supervisor and authorised representative of TL.

Q: Please point the accused in court.

Q: How long have you been a supervisor?

A: Two years

Q: As a supervisor, what are your duties and responsibilities?

A: _____________

Establish job description of the accused

Q: What is the job accused Magat and Reyes at Tong Lung?

A: They are machine operators at the A2 Department of TL.

Q: As machine operators of the A2 Department of TL, what do they do?

A: ________

Q: As machine operators of the A2 Department of TL, where do they work?

A: At TL Plant 1.

Q: Can they enter TL Plant 1, then?

A: Yes.

Q: What happens, if any, if a person who is not working at TL Plant 1 enters TL

Plant 1?

A: They cannot enter TL Plant 1.

Q: Why?

A: The guard on duty at the gate of TL Plant 1 will prevent you from entering /
accessing TL Plant 1.

Q: How?

A: ____________

Q: You mentioned that accused Magat and Reyes are machine operators at TL
Plant 1. What happens then, if any, if they attempt to enter TL Plant 1?

A: Since they are machine operators at TL Plant 1, they can freely enter TL Plant
1.

Establish access to the stolen items

Q: You mentioned that you filed a Complaint against accused Magat and Reyes.
What prompted you to file the Complaint?

A: The accused were caught red handed stealing Tong Lung property, consisting
of scrap copper grains and keys worth approximately PhP 7,800.00

Q: What company property if you know?

A: Scrap copper and keys.

Q: If I will show a photo of the scrap copper and keys, would you be able to
identify them?

A: Yes.

Q: I am showing you a photograph of the seized scrap copper grains and keys
inside the 11 pairs of white gloves marked as Exhibits "A-K" with initials
"RA-RL-MDV," previously marked as Exhibit "__". Are these the scrap
copper and keys that you mentioned that accused stole?

A: Yes.

Q I am showing you a photograph of seized scrap copper grains and keys inside
the one pair of blue/orange Nike shoees marked as Exhibits "L-L1" with
initials "RA-RL-MDV," previously marked as Exhibit "__". Are these the
same scrap copper and keys that you mentioned that accused stole?

A: Yes.

Q: You mentioned accused stole scrap copper and keys company property.
Where, if you know, are the scrap copper and keys located inside TL?

A: In A2 Extension Building at TL Plant 1.

Q: Why are they located there?

A: The scrap copper grains and keys are used in the processing of keys at TL
Plant 1.

Q: What is the relation, if any, of the A2 Extension Building here to the job of
the accused?

A: The A2 Extension Building is inside TL Plant 1. Since the accused are

employees of the A2 Department, they can enter TL Plant 1. Thus, they have
access to the A2 Extension Building where the stolen items are located. The
accused could not have accessed the A2 Extension Building where the items
are located if they are not employees of the A2 Department.

Establish grave abuse of confidence

Q: You testified that accused Magat and Reyes have access to the stolen items
here. How then, if you know, does TL treat employees of the A2 Department,
like accused Magat and Reyes?

A: Since they have access to the stolen items here, Tong Lung has imbued the
position of doorknob machine operator with a very high degree of trust and
confidence. This is because they have access to expensive company property
in their daily tasks.
Q: Did the accused Magat and Reyes gravely abuse their position as employee of
A2 Department.

A: Yes

If objected to as leading

Q: What is the significance of their position as employee of A2

Department in this case?

A: Accused Magat and Reyes gravely abused their position as employee

of the A2 Department.

Q: Why do you say so?

A: Their job as doorknob machine operators is essential to the taking of the stolen
items because it enabled them to have easy access to the stolen items here.
They were able to enter Tong Lung Building A and to take the stolen items
therein precisely because they are doorknob machine operators. Hence, they
could not have committed this crime where it not for their position as a
doorknob machine operators at Tong Lung.

Identification and Authentication Questions

Q: Certificate of Employment (Exhibit "G")

Q: Certificate of Ownership (Exhibit "H")

Q: Secretary's Certificate (Exhibit "I")