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Republic of the Philippines Department of labor and Employment National Labor Relations Commission Regional Arbitration Branch No.

XI Davao City

WARLORD JOHN R. CERVANTES Complainant, NLRC CASE NO. RAB XI 08-00883-10 For: ILLEGAL DISMISSAL WITH MONEY CLAIMS -versusVITARICH CORPORATION/ GROMAX, INC., et. a. Respondent, x---------------------------------x

POSITION PAPER COMPLAINANT, thru the undersigned counsel, and unto this

Honorable Office, respectfully submits this Position Paper.

PREFATORY STATEMENT The employers prerogative of terminating its employees in the implementation of its management policies and protection of its interests is not without limitations. Labor laws provide not only the valid causes for which an employer may order the dismissal of an employee, but also the proper manner in exercising such right to dismiss. And herein complainant was dismissed arbitrarily, and in a manner contrary to what is mandated by law, hence, this position paper.

PARTIES COMPLAINANT WARLORD JOHN R. CERVANTES (hereinafter

referred to as CERVANTES for brevity) is a Filipino, married, of legal age, and a resident of Block 6, Lot 12, Southvilla Country Homes, Ma-a, Diversion Road, Davao City and may be served with pleadings, orders and other processes of this Honorable Office thru the undersigned counsel.

VITARICH CORPORATION / GROMAX, INC. (hereinafter referred as VITARICH for brevity) is a corporation existing under Philippine laws and is engaged in the business of manufacturing and selling of animal feeds and health products to its consumers. It is represented by ROGER M. SARMIENTO, as its owner; ROCCO M. SARMIENTO, as General Manager; STEPHANIE NICOLE S. GARCIA, as Finance Manager; GUILLERMO B. MIRALLES, as Vice President for Vis-Min Operations; AIDA T. GIRADO, as Administrative Manager; DIANA C. CONCEPCION, as Human Resource Supervisor for Vis-Min; and MARICEL L. MUSONES, as Human Resource Manager. It is located at Km. 14, Panacan, Davao City where it may be served with pleadings, orders, and other processes of this Honorable Office.

ANTECEDENT FACTS 1. Complainant CERVANTES was employed by respondent VITARICH as a Regional Sales Manager (RSM for brevity) for Cebu Feed Sales Operations on April 15, 2006 with a salary rate fixed at P42,500.00 per month;

2. As RSM, CERVANTES function was primarily and essentially to

monitor and ensure that the target sales and collections of the

District Sales Managers (DSM for brevity) under his supervision are reached (Job Descriptions Manual for RSM is herein attached as Annex A to A-1);

3. Sometime in April 2009, CERVANTES was verbally informed of his

transfer to Mindanao as RSM for General Santos Feed Sales Operations;

4. Prior to the effectivity of such transfer, there was a transition period

during which CERVANTES underwent orientation from a certain BERNARDO TANIZA (TANIZA for brevity), the then RSM for General Santos Feed Sales Operations;

5. That CERVANTES officially assumed office as RSM for General Santos Feed Sales Operations only on May 1, 2009;

6. In April 2009, during the tenure of TANIZA as RSM, one DSM, a

certain GRACE C. NECOR (NECOR for brevity), conducted the alleged questioned transactions of selling and causing the delivery of VITARICHs products to a certain MILAGROS TAMAYO, who at that time does not have an approved credit line with VITARICH;

7. Also prior to complainant CERVANTES tenure as RSM for General Santos, similar transactions of selling and causing the delivery of VITARICHs products to a certain ROSALINA FARM were effected despite the latters lack of a credit line or during the pendency of their application for a credit line;

8. To facilitate such sales despite the lack of a credit line, NECOR

issued invoices under the name and account of an existing client with an approved credit line, the DOA JOSEFA FARM owned by one JOSIE GARCIA;

9. TAMAYO FARM transacted with respondent VITARICH under the name of DOA JOSEFA FARM only until May 8, 2009, as complainant already completed the processing of TAMAYO FARMs application for a credit line on May 11, 2009;

10. Sometime in December 2009, NECOR, in a letter dated December

12,

2009,

addressed

to

complainant

and

other

officials

of

respondent VITARICH, herein attached as Annex B, admitted to conducting the said transactions;

11.

NECOR justified her transactions by explaining that allowing a

client without an approved credit line to purchase and place orders under the name of another client who has an approved credit line is an accepted company practice for the purpose of promoting and developing new customers or accounts;

12. That the questioned transactions were done with the knowledge

and consent of JOSIE GARCIA (Audit Report, refer to Annex A of Respondents Position Paper), subject to the condition that it is still the DSM who will handle collections from the other clients purchasing under the name of DOA JOSEFA FARM;

13.

Upon Confirmation of Accounts by respondent VITARICH, JOSIE

GARCIA denies having placed the orders, since the orders were actually made by TAMAYO FARM and ROSALINA FARM, but does not deny consenting to the arrangement;

14.

TAMAYO FARM, along with other clients, refused to pay for the

purchased products and asked for an adjustment of the balance as compensation for the losses incurred by them due to the production and delivery by respondent VITARICH of low quality feeds;

15. That such allegation of the products having low quality is supported

by the findings of respondents quality assurance department personnel, JESUS C. CARIN, JR as stated in his letter, herein attached as Annex C;

16.

That complainant CERVANTES, thereafter, openly criticized the

Vice President for Vis-Min Operations, GUILLERMO B. MIRALLES (MIRALLES for brevity), for the production low quality products;

17. In January 2010, CERVANTES received a Notice to Explain (Refer to

Annex B of Respondents Position Paper), dated January 5, 2010, issued only by MIRALLES, and not by the Human Resource Department, directing the former to explain, in a letter, the charges against him in relation to the unpaid sales and deliveries made to TAMAYO FARM and ROSALINA FARM, when both clients do not have approved credit lines;

18. That the complainant was

wrongfully designated in the Notice to

Explain (Refer to Annex B of Respondents Position Paper) as a District Sales Manager (DSM for brevity), and the charges therein were related to the functions of a DSM as well (Job Description Manual for DSM is herewith attached as Annex D to D-1);

19. Complainant CERVANTES submitted his reply (Refer Annex C of

Respondents Position Paper) denying all allegations;

20. Nevertheless, respondent VITARICH through MIRALLES, and not

through

its

Human

Resource

Department,

sent

complainant

CERVANTES a Notice of Decision (Refer to Annex D of Respondents Position Paper) informing the latter that his employment is being terminated;

21.

Such termination is not supported by substantial proof that

complainant is indeed guilty of the charges, the evidence are purely fabricated statements or, at best, hearsay;

22. Complainant

was not given opportunity to be heard before

VITARICHs Administrative Investigation Committee to which every company employee, rank and file or managerial, was entitled to as a matter of company policy;

23. Complainant CERVANTES is also entitled to shares of stocks valued

at P7,200.00 per month as provided in his Letter of Appointment,

herein

attached

as

Annex

E,

and

Appointment

&

Pay

Authorization, herein attached as Annex F, the value of which, respondent VITARICH has failed to release to complainant;

24. Complainant CERVANTES is also entitled to the ownership of the

company vehicle subject of the car plan provided for in his Letter of Appointment (Annex E to E-1) and Appointment & Pay Authorization (Annex F), already having fully paid for the same;

ISSUE 1) Whether dismissed. 2) Whether the complainant is entitled to reinstatement and backwages.
3) Whether or not Complainant is entitled to receive the value of

or

not

Complainant

CERVANTES

was

illegally

shares of stocks and ownership over the company car. 4) Whether the complainant is entitled to moral and exemplary damages and attorneys fees

ARGUMENTS AND DISCUSSIONS ON THE FIRST ISSUE: 1. THE COMPLAINANT WAS ILLEGALLY DISMISSED. 1.A. COMPLAINANT IS A MANAGERIAL EMPLOYEE OF VITARICH AT THE TIME HIS DISMISSAL WHO ENJOYS SECURITY OF TENURE, AS PROVIDED BY LAW.

To begin with, it must be stressed that CERVANTES was a regular employee until the time that he was illegally dismissed from his

employment. Article 280 of the Labor Code of the Philippines provides: Art. 280. Regular and Casual Employment. The provisions of written agreement to the contrary notwithstanding and regardless of the oral

agreement of the parties, an employment shall be deemed to be regular where the employee has been engaged to perform activities which are usually necessary or desirable in the usual business or trade of the employer, xxx Provided, that any employee who has

rendered at least one year of service, whether such service is continuous or broken, shall be considered a regular employee with respect to the activity in which he is employed and his employment shall continue while such activity

exists. (Emphasis supplied). The primary standard to determine a regular employment is the reasonable connection between the particular activity performed by the employee in relation to the usual business or trade of the employer. The test is whether the former is usually necessary or desirable in the usual business or trade of the employer.
1

De Leon vs. NLRC, GR No. 70705, Aug. 21, 1989

By virtue of the nature of

his employment as stated above, the necessary or desirable in the

activities that complainant performed are

usual business or trade of VITARICH as engaged in the business of manufacturing and selling of animal feeds and health products to its consumers. It can be gleaned further by their individual length of service to VITARICH, which obviously exceeded the statutory period of at least one (1) year of service, Complainant was indeed a regular employee of VITARICH when the was dismissed from their employment. Furthermore, Article 279 of the Labor Code of the Philippines provides: Art. 279. Security of Tenure. In cases of regular employment, the employer shall not

terminate the services of an employee except for a just cause or when authorized by this Title. x x x While the aforementioned provision finds better application to regular rankand-file employees, it is not, however, completely without application to managerial employees. Jurisprudence dictates that even managerial employees are entitled to security of tenure. While an employer has its own interests to protect, and pursuant thereto, it may terminate a managerial employee for a just cause, such prerogative to dismiss or lay off an employee must be exercised without abuse of discretion. Its implementation should be interpreted with compassion and understanding. The employer should bear in mind that in the execution of said prerogative, what is stake only is not only the employees position but his livelihood. The fact that one is a managerial employee does not by itself exclude him from the protection of the constitutional guarantee of security of tenure.(Maglutac v NLRC, Commart [Phil.] Inc., G.R. No 78345, Sept 21, 1990)
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1.B THE CAUSES FOR DISMISSAL WERE NOT SUBSTANTIALLY PROVEN. The power to dismiss is the normal prerogative of the employer and generally, the latter may dismiss his employees for just and authorized cause. However, the employer is bound to exercise caution in terminating the services of his employees and must not be arbitrary and capricious.
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Article 282 of the Labor Code provides for just causes in which an employer may terminate his employee: a) Serious misconduct or willful disobedience by the employee of

the lawful orders of his employer or representative in connection with his work; b)
c)

Gross and habitual neglect by the employee of his duties; Fraud or willful breach by the employee of the trust reposed in

him by his employer or duly authorized representative d) Commission of a crime or offense by the employee against the

person of his employer or any immediate member of his family or his duly authorized representative; and e) Other causes analogous to the foregoing.

As a general rule, employers are allowed wider latitude of discretion in terminating the employment of managerial personnel or those who, while not of similar rank, perform functions which by their nature require the employer's full trust and confidence. This must be distinguished from the case of ordinary rank-and-file employees, whose termination on the basis of these same grounds requires a higher proof of involvement in the events in question; mere uncorroborated assertions and accusations by the employer
2

Rance, et al. vs. NLRC, GR No. 68147, June 30, 1988


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will not suffice. (Coca-Cola Bottlers Philippines, Incorporated vs. NLRC, et. Al, G.R. No. 84075, April 25, 1989). While the charges alleged by respondent VITARICH constitute

violations of Art. 282, Par. (c), VITARICH nevertheless, failed to substantially prove the same. First and foremost, the alleged questionable transactions could not have been performed by complainant as they do not pertain to the functions and responsibilities of complainant. In fact, the Notice to Explain (Refer to Annex B of Respondents Position Paper) received by CERVANTES was addressed to a District Sales Manager, and the charges therein are mainly for selling and delivering products to clients without credit lines which are essentially functions of a DSM as a sales agent. Respondent VITARICHs DSM Job Descriptions Manual (Annex D) provides that the DSMs duties and responsibilities include opening new accounts, coordinate with the Feed Production Section to ensure the availability of stocks for delivery, facilitate the sales and deliveries of the products, and prepare and submit reports. While complainants duties and functions as Regional Sales Manager, on the other hand, is primarily to help the DSM in promoting VITARICHs products to customers, and monitor the sales and collections of the DSM based on the latters reports. Clearly, any unauthorized sales could not be attributed to the RSM. This is further evidenced by the letter, dated December 12, 2009, made by DSM NECOR, admitting that it was her who arranged for the sales to be made under the name of another account which is JOSIE GARCIA (Annex B). Moreover, the sales involved in the allegations occurred before complainant CERVANTES tenure as RSM for Gen. Santos began, and during such time when complainant was still the RSM for Central Visayas.

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The allegations of connivance to conceal the said transactions from the knowledge of respondent VITARICH must also fail in the face of substantial evidence to the contrary. If there really was an attempt to conceal the transactions, DSM NECOR, would not have had the representative of TAMAYO FARM sign the Delivery Receipts and Sales Invoices, such act controverts the entire theory of concealment. And if respondent company truly had no knowledge of said transactions, then JUSTINO H. GARSUTA (GARSUTA for brevity) of the Credit and Collection Department could not have sent a bill addressed directly to MILAGROS TAMAYO. This proves that respondent VITARICH, in fact, had knowledge that deliveries were made not to JOSIE GARCIA, but to MILAGROS TAMAYO. Furthermore, granting, for the sake of argument, that there was connivance, complainant CERVANTES could not have been part of it. As previously stated, complainants role, in relation to sales, is limited to managing the sales team by monitoring the same through the reports prepared and submitted by the DSM. Looking into the process flowchart of respondent VITARICH, the DSM refers the sales and orders to the Credit and Collection Department, headed by GARSUTA, to determine the status of the clients credit line. Upon approval by the latter, the order is then referred to the Accounting Department for further processing. From there, it is then subjected to the approval of the Field Sales Manager, ALBERTO O. OPPUS (OPPUS for brevity), and lastly, to MIRALLES. And finally upon approval, it is GARSUTA who instructs the stocks custodian, a certain BUBONG BENITEZ, to release the products for delivery. Nowhere in the processing of sales and deliveries is complainant CERVANTES approval required. Thus, respondent VITARICH could not possibly present documentary evidence showing CERVATES direct involvement in the questioned transactions.

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Respondents only basis for complainants involvement as shown in the formers Audit Report (Refer to Annex A of Respondents Position Paper), is the alleged statement of NSC NECOR that CERVANTES had knowledge of such transactions. This is once again belied by NECORs letter (Annex B), which was addressed to the complainant, admitting to the performance of such transactions and explaining the reason for such. Complainant CERVANTES also could not be said to have been remiss in the performance of his duties, for although respondent VITARICH, through the DSM NECOR, has been selling and delivering products to the TAMAYO FARM, the latter only became an official client of respondent when complainant processed the application of TAMAYO FARM for a credit line, which was subsequently approved on May 11, 2009, herein attached as Annex G to G-1. Furthermore, complainant CERVANTES was among those who recommended that legal action be taken against MILAGROS TAMAYO for non-payment of her outstanding balance, herein attached as Annex H. Having stated all that, it is noteworthy that the questioned

transactions were a series of sales that transpired over a period of time. Had it been a one-time transaction, it would have raised the possibility that there could, in fact, be an attempt to conceal the transaction. But seeing as the transactions went on for a certain period, it would be logical to believe that by the time TAMAYO FARM and ROSALINA FARM had placed their subsequent orders, the approving authorities shall have already noticed that the Delivery Receipts and Sales Invoices, while under the name of JOSIE GARCIA, were actually signed and acknowledged by a different client. This would show that the authorities such as GARSUTA and MIRALLES, approved such orders even when the previous Receipts and Invoices contained

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discrepancies, or were signed by a different client. These circumstances should confirm the theory that selling to and placing orders for clients without a credit line, under the names of clients with credit lines, is indeed an accepted company practice. Otherwise, it should be the aforementioned authorities who approved such sales and orders that should be held liable for negligently approving the same despite the existence of anomalies in the previous sales invoices and delivery receipts. 1.C. COMPLAINANT WAS NOT ACCORDED PROCEDURAL DUE

PROCESS. Based on the facts stated, it is apparent that the complainants were not accorded procedural due process. Granting arguendo that the dismissal was founded on any of the said grounds, the same is still considered as illegal for want of compliance with the procedural process of dismissal. If the employee committed an act which was a lawful cause or justification for his dismissal, the employer should give him the opportunity to explain or present his side. There should not be an outright termination of the services of the employee without affording him due process3. It is further required by the Implementing Rules of Book 6, Rule 1, Paragraph (d) of Department Order No. 9 Series of 1997 of the Department of Labor and Employment, that the following shall be observed: 1. A written notice served on the employee specifying the ground/s for termination, and giving said employee reasonable opportunity within which to explain his side; 2. A hearing or conference during which the employee concerned, with the assistance of the counsel if he so desires is given Robusta Agro Marine Products, Inc. vs. Gorombalem, GR No 80500, July 5, 1989
3

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opportunity to respond to the charge, present his evidence, or rebut the evidence presented against him; 3. A written notice of termination serve on the employee, indicating that upon due consideration of all circumstances, grounds have been established to justify his termination. In addition to these requirements provided for by existing laws and jurisprudence, respondent VITARICHs own policies provides that the existence of causes to penalize and/or terminate an employee must be determined by their Administrative Investigative Committee. In

complainants case, however, all the aforementioned requirements were capriciously bypassed by MIRALLES. In terminating complainant, MIRALLES issued a Notice to Explain (Refer Annex B of Respondents Position Paper), without being sanctioned by their Human Resource Department, requiring complainant explain, in a letter, the charges against the latter. Clearly, this is not the hearing or conference contemplated by law. Subsequent thereto, MIRALLES, again without being sanctioned by the Human Resource Department, and upon his own discretion, issued the Notice of Decision (Refer to Annex D of Respondents Position Paper), terminating complainants employment. Jurisprudence dictates that while a managerial employee may be dismissed merely on the ground of loss of confidence, the matter of determining whether the cause for dismissing an employee is justified on the ground of loss of confidence cannot be left entirely to the employer.4 It is also worth mentioning that prior to complainants termination, there was already a rising conflict between complainant CERVANTES and MIRALLES. This was due to the fact that the former has been criticizing
4

De Leon vs. National Labor Relations Comission, 100 SCRA 691 (1980)
15

MIRALLES performance as Vice President for Vis-Min Operations for allowing the manufacture and sale of low quality products, which the complainant substantiated through the expert findings (Annex C) of respondent VITARICHs own quality assurance personnel. These circumstances indicate bad faith on the part MIRALLES in capriciously and immediately dismissing complainant CERVANTES to the prejudice of the latters right to procedural due process. ON THE SECOND ISSUE 2. COMPLAINANTS ARE ENTITLED TO REINSTATEMENT WITH

BACKWAGES Since the complainant was illegally dismissed from his employment, he is entitled to reinstatement plus backwages. Article 279 of the Labor Code of the Philippines provides that an employee who is unjustly dismissed from work is entitled to reinstatement without loss of seniority rights and other privileges and to his full backwages, inclusive of allowances, and to his other benefits or their monetary equivalent computed from the time his compensation was withheld from him up to the time of his actual reinstatement. Backwages, in general, are granted on grounds of equity for earnings which a worker or employee has lost due to his illegal dismissal5. Clearly, as respondent VITARICH failed to comply with the

requirements of due process, both procedurally and substantively, the complainant was illegally dismissed. Hence, the complainant is entitled to reinstatement and backwages computed from the actual period when the complainant was unlawfully prevented from working.
5

Torillo vs. Leogardo GR No. 77205, May 27, 1991


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ON THE THIRD ISSUE 3. COMPLAINANTS ARE ENTITLED TO THE FOLLOWING CLAIMS: 3.A Value of shares of stocks: Upon his employment, a Letter of Appointment (Annex E) and Appointment & Pay Authorization (Annex F) was issued by respondent VITARICH, stating that part of his monthly benefits shall be shares of stocks of respondent VITARICH valued at P7,200.00. The same, however, was not released to him upon his termination. And having been earned by complainant during his employment, he has a vested right over said shares of stocks which cannot be prejudiced by his termination. 3.b Ownership over the company car: Also provided in complainant CERVANTES Letter of Appointment (Annex E) and Appointment & Pay Authorization (Annex F) was the grant of a car plan, valued at P437,500.00 worth of car loan credits. However, the vehicle subject of complainants car plan was appraised only for P300,000.00. Although the plan was for a 5-year term, the deductions and amortizations were computed and fixed on the basis of the P437,500.00 car plan. Hence, after being employed for three (3) years and four (4) months, the amortizations shall have sufficed to fully pay for the subject vehicle, and ownership thereof rightfully belongs to complainant. ON THE FOURTH ISSUE 4. COMPLAINANTS ARE ENTITLED TO DAMAGES 4.A. Moral Damages The fact that complainant was not afforded of both substantive and procedural due process on their arbitrary dismissal, it is but proper for them to be awarded moral damages.

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The employer is liable for damages under the provisions of Article 2220 of the Civil Code providing for damages for breach of contract where the employer acted fraudulently or in bad faith.6 Ergo, where the dismissal of the employee was attended by bad faith or constituted an act oppressive to labor, or was done in a manner contrary to morals, good customs or public policy, an award of moral damages is justified. Evidently, the foregoing are present in this instant case due to the failure of VITARICH to observe the requirements of both substantive and procedural due process. 4.B. Exemplary Damages Where the employees dismissal was effected without substantive and procedural fairness, an award of exemplary damages in their favor can only be justified if her dismissal was effected in a wanton, oppressive or malevolent manner.7 Inasmuch as the manner in which the complainant was dismissed was done in a wanton, arbitrary and unjustifiable manner, they are entitled to exemplary damages. 4.C. Attorneys Fees Complainants was compelled to litigate and incur expenses to protect and vindicate their rights. Hence, it is only proper that attorneys fees be awarded equivalent to ten percent (10%) of the claims of the complainants.

CLLC E.G. Gochangco Workers Union, et. al.vs. NLRC, GR No. 67258, May 30,1988 7 Roche Philippines vs. NLRC, GR. No. 832335, Oct. 95, 1989
6

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PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Labor Arbitration Branch to render judgment in favor of complainant declaring his dismissal illegal and order respondents the following:

1. the reinstatement of complainant with backwages;

2. the delivery of shares of stocks and the company vehicle subject of the car plan policy to complainant;
2. the payment of separation pay, in lieu of reinstatement; 3. to pay moral and exemplary damages; and

4. Attorneys Fees

Complainant further prays for other relief just and equitable.

RESPECTFULLY SUBMITTED this ___ day of November 2010 in Davao City, Philippines.

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ATENEO LEGAL SERVICES OFFICE Counsel for the Complainant 2F Dotterweich Hall Jacinto Street, Davao City 8000 Tel. No. (082) 227-7460 BY:

Jose Karlo Caballero II Karen Cate Ilagan Hanna Jane Pernes Daryl Ritchie Valles

Charnem Caete Hannah Khiarra Linog Christian Paul Pinote

Legal Interns (as per Supreme Court Resolution No. 449 Dated September 29, 1988)

Under the Control and Supervision of:

Atty. Manuel P. Quibod Roll of Attorneys No. 33499 PTR No. 8442955, 01-04-10, D.C. IBP Lifetime Member Roll No. 00996 MCLE Exemption No. III-00745

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Republic of the Philippines) C I T Y O F D A V A O ) s.s. x ----------------------------------x


VERIFICATION and CERTIFICATION OF NON-FORUM SHOPPING

I, WARLORD JOHN R.CERVANTES,, of legal age, Filipino and a resident of Davao City, upon my oath, depose and state THAT:

1. I am the complainant in the above-entitled case; I have caused the preparation of this Position Paper; and I have read the contents hereof and declare that the same to be true and correct based upon authentic records obtained in this case. 2. I CERTIFY FURTHER that I have not therefore commenced any other action or proceeding involving the same issues in the Supreme Court, Court of Appeals, or any tribunal or any agency; 3. To the best of my knowledge, no such action or proceeding is pending in the Supreme Court, Court of Appeals, or any other Tribunal or agency;

4. If there is any such action or proceedings which is either pending or may have been terminated, I will state the status thereof; and 5. If thereafter I learn that a similar action or proceeding has been filed or is pending before the Supreme Court, Court of Appeals, and any other tribunal or agency, I undertake to report that fact within five (5) days there from to the Court or agency, wherein the original pleading and sworn certification contemplated herein have been filed.

In witness whereof, I hereby affix ____________________, at Davao City, Philippines.

my

signature

this

____________________________ WARLORD JOHN R.CERVANTES Affiant

SUBSCRIBED AND SWORN TO before me this ____________________, at Davao City, Philippines. Affiant exhibited to me his Community Tax Certificate with 21

number ___________________, issued on ______________, issued by the City of Davao.

Doc. No. :_______; Page No.:_______; Book No.:_______; Series of 2010.

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