Republic of the Philippines

NATIONAL LABOR RELATIONS COMMISSION

Regional Arbitration Branch No.

A,
Complainant,

-versus- NLRC CASE NO. ____

B
Respondents.
x-----------------------------------------------------------x

POSITION PAPER
(For the Complainant)

Complainant ______, through the undersigned _________,

submits his Position Paper and respectfully states that:

I. STATEMENT OF THE CASE

This is an action for illegal dismissal, nonpayment Holiday

Pay, Premium for Holiday and Rest Day, Service Incentive Leave,
13th Month Pay, Separation Pay, Backwages, and Attorneys Fees.

II. THE PARTIES

2.1. Complainant _______ is of legal age, Filipino, married,

and with residence at ___________

2.2. The complainant may be served with orders,

resolutions and other processes of this Honorable Office through
the undersigned counsel at the addressed indicated hereafter.

2.3. Respondent ________ holds its principal place of

business at ____________

2.4. Respondent _______ is the manager of the respondent

company.

III. STATEMENT OF THE FACTS

3.1. By way of statement of facts, attached hereto as

ANNEX A is the Sinumpaang Salaysay of Complainant _________.

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 IV. ISSUES

4.1. Whether or not the complainant was illegally

dismissed
4.2. Whether or not the complainant is entitled to the
payment of holiday pay, premium for rest day, service
incentive leave, 13th month pay, separation pay, backwages
and Attorneys fees.

V. DISCUSSION

Complainant was
illegally dismissed
by the respondent
company

Complainant is entitled
to Separation Pay

Complainant is entitled
to the payment of backwages

COMPLAINANT IS ENTITLED TO
HOLIDAY PAY AND RESTDAY

COMPLAINANT IS ENTITLED TO PREMIUMS

FOR HOLIDAY AND REST DAY

Complainant is entitled
to Service Incentive Leave

Complainant is entitled
to 13th Month Pay

Complainant is entitled to
Moral and Exemplary Damages,
and Attorneys Fees

WHEREFORE, premises considered, it is most respectfully

prayed that the claims of the complainant for Illegal Dismissal,
back wages, separation pay, nonpayment of Holiday Pay,
Premium for Holiday and Rest Day, Service Incentive Leave, 13 th
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Month Pay, Moral and Exemplary Damages, and Attorneys Fees
be GRANTED.

Other reliefs that are just and equitable under the

circumstances are likewise prayed for.

LAW OFFICE

By:

Copy furnished:

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