REPUBLIC OF THE PHILIPPINES )

PROVINCE OF ZAMBOANGA DEL NORTE )S.S

Municipality of Sindangan )
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POSITION PAPER

COMES NOW, the complainant, EUSEBIO PANDOG GUMAGA,

unto this Honorable Office, most respectfully avers and states: THAT-

1. The complainant is EUSEBIO PANDOG GUMAGA, of legal age,

married to LYDIA SAMUYAG GUMAGA, Filipino, a retired construction
worker, and a resident in Mangilay, Siayan, Zamboanga del Norte,
Philippines;

2. I am the complainant in one labor case now pending before this

Honorable Office against E. GANZON Incorporated with official address at
7th Floor, EGI Rufino Building, Pasay City;

3. I filed the instant case because I was not paid of my backpay which
was due and demandable when I worked in the said Company;

4. I first started working in EG Incorporated on January, 2002 until

December, 2003 in EGI Taft Tower Company, Manila as a Laborer;

5. In 2004 and 2005, I stopped working because I got sick and was not
able to do physical labor;

6. However, on 2006, Engr. Valenzuela of the said company called me

up and offered me to work again in the same company. Thus, on March 1,
2006, I started working in Baguio City under EGI Albergo Di Ferroca
Construction as a laborer and thereafter as housekeeper;

7. I worked as such until January 31, 2013. On April 1, 2013, the said
company transferred me as a maintenance worker in the said building until
my retirement on April 15, 2017;

8. The company paid me only Php 2,000.00 Philippine Currency as a

backpay of all my works in the said company. However, I learned that I should
have received Php5,000.00 for each year that I worked for the said company;

9. I believe that I should have received a total amount of Php45,000.00

Philippine Currency for all the necessary works I have done to the company;

10. I demanded for payment for all my backpay, however, until present,
the company has refused to heed to my demand;

11. Thus, I filed the instant complaint.

 PRAYER

PREMISED ON THE FOREGOING, the undersigned respectfully

prays that the company, E. GANZON INCORPORATED pay the total back
pay due to the undersigned and all the interests accruing thereto. He further
prays that the company pay all the necessary amounts due to the undersigned
when he retired from the said company.

Other just and equitable remedies are also prayed for.

Siayan, (for Baguio City), Zamboanga del Norte, Philippines.

EUSEDIO P. GUMAGA
Affiant

Republic of the Philippines )

PROVINCE OF ZAMBOANGA DEL NORTE )S.S.
Municipality of Siayan )
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VERIFICATION AND CERTIFICATION

ON NON-FORUM SHOPPING

I, EUSEDIO P. GUMAGA, of legal age, married to LYDIA

SAMUYAG GUMAGA, Filipino, a retired construction worker, and a
resident in Mangilay, Siayan, Zamboanga del Norte, Philippines , under
penalty of perjury hereby declare under oath:

1. That I am the affiant in this Position Paper;

2. That in such capacity, I have caused the preparation and filing of

this Position Paper;

3. That I have supplied all the allegations contained therein and the
same are true and correct to the best of my own personal knowledge and
based on authentic documents;

4. That I hereby certify under oath that I have not commenced any
other action or proceeding involving the same issue in the Supreme Court,
Court of Appeals or any other tribunal or agency; That to the best of my own
personal knowledge, no such action or proceeding is pending in the
Supreme Court, Court of Appeals or any tribunal or agency; and that if I
should thereafter learn that a similar action or proceeding has been filed or
is pending before the Supreme Court, Court of Appeals or any other tribunal
or agency, I undertake to report the fact within five (5) days therefrom to this
Honorable Court.
 IN WITNESS WHEREOF, I have hereunto affixed my signature this
_____________________ at Siayan, Zamboanga del Norte, Philippines.

EUSEDIO P. GUMAGA
Affiant

SUBSCRIBED AND SWORN to me this March 3, 2018, affiant

personally came and personally known to me as the same person who
signed the foregoing instrument before me and avowed under penalty of law
to the whole truth of the contents of said instrument. WITNESS MY HAND
AND SEAL the date and place above-written.