REPUBLIC OF THE PHILIPPINES

METROPOLITAN TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
BRANCH 43, QUEZON CITY

PEOPLE
OF
PHILIPPINES,

THE
Plaintif,
Criminal Case No. 1403523
For: Perjury

-versusJESSY ENDIOLA,
Accused.

x--------------------------------------------------x
COMPLAINT-AFFIDAVIT
I, STEVEN S. GRIMES, of legal age, Filipino and
with business address at Room 701, MCT Tower Center
6772 Ayala Avenue, Makati City 1226, after being first
duly sworn, depose and state:
1. I am the President of MOUNTAIN MINERAL
RESOURCES, CORPORATION (hereinafter, MMRC), a
corporation duly organized and existing under
Philippine laws and owns or has rights to acquire a
portfolio of seven gold and porphyry copper-gold
projects in the Philippines.
2. The Corporations principal office address is located
at Room 701, MCT Tower Center 6772 Ayala Avenue,
Makati City 1226.
3. I am duly authorized by the Board of Directors of the
Corporation to file this Complaint-Affidavit on its
behalf and to perform any and all acts in furtherance
of such purpose. A copy of the Secretarys
Certificate authorizing me to do so is hereto
attached as Annex A.
4. The Accused Endiola executed a Complaint/ Request
for Assistance dated 3 August 2013 in Jessy E.
Endiola vs. Mountain Mineral Resources Corporation,
Steven S. Grimes and David O. Briz docketed as
National Labor Relations Commission or NLRC Case
No. NCR-08-11713.
5. The Complaint/ Request for Assistance dated 3
August 2013 was subscribed and sworn to by the
accused before a person authorized to administer an
oath.
2

6. The Accused Endiola executed a Complaint dated 3

August 2013 in Jessy E. Endiola vs. Mountain Mineral
Resources Corporation, Steven S. Grimes and David
o. Brix docketed as NLRC Case No. NCR-08-11713.
7. The Complaint dated 3 August 2013 was subscribed
and sworn to by the accused before a person
authorized to administer an oath.
8. The Accused Endiola executed a Complaint/ Request
for Assistance dated 18 December 2013 in Jessy E.
Endiola vs. Mountain Mineral Resources Corporation,
Steven S. Grimes and David O. Brix for NLRC RAB No.
NCR Case No. NCR-12-18240-12.
9. The Complaint/ Request for Assistance dated 18
December 2013 was subscribed and sworn to by the
accused before a person authorized to administer an
oath.
10.
The
accused
executed
a
Verification/Certification of Non-Forum Shopping as
part of the Complaint/ Request for Assistance dated
18 December 2013.
11.
The Accused Mangaoang executed a Complaint
dated 18 December 2013 in Jessy E. Endiola vs.
Mountain Mineral Resources Corporation, Steven S.
Grimes and David O. Brix which is docketed as NLRC
RAB No. NCR Case No. NCR-12-18240-12.
12.
The Complaint dated 18 December 2013 was
subscribed and sworn to by the accused before a
person authorized to administer an oath.
13.
The accused executed the Verification and
Certification of Non-Forum Shopping as part of the
Complaint dated 18 December 2012.
14.
At the time material to the case, the work place
of accused is at Masapelid Island, Barangay Layab
Ellaperal, Surigao del Norte, Mindanao.

15.
At the time material to the case, the work
schedule of the accused is 6 week straight/ 2 weeks
vacation.
At the time material to the case, the address of Mountain
Mineral Resources is at 24th Floor Manduae Building 39
Makati Avenue, Makati City.
FURTHER AFFIANT SAYETH NAUGHT.

STEVEN S. GRIMES
Affiant
SUBSCRIBED AND SWORN to before me this 25 day
of October 2015 in the City of Quezon City.

Investigating
Prosecutor

I CERTIFY THAT I have personally examined the

affiant and I am satisfied that he voluntarily executed and
understood the contents of the foregoing ComplaintAffidavit.

Investigating
Prosecutor