REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF LABOR AND EMPLOYMENT

NATIONAL LABOR RELATIONS COMMISSION
QUEZON CITY

RONNEL DE LEON
STA.ANA,
Complainant,
NLRC NCR Case No. 04-05879-18
- versus – Hon.Imelda C. Alforte-Ganancial

BRADY PHARMA, INC.,

Respondent.
x-----------------------------------------------------------------------------------------x

REPLY
(Re: Position Paper for the Respondents
dated 14 August 2018)

Complainant RONNEL DE LEON STA. ANA, by counsel,

pursuant to Section 12(d), Rule V of the 2011 NLRC Rules of
Procedure and in compliance with this Honorable Office’s directive
during the conference held on 23 August 2018, respectfully submit
this Reply, and in support thereof state:

PREFATORY STATEMENT

“xxx labor pronouncements must be read and applied with utmost

care and caution, taking to mind that in the very heart of the judicial system,
labor cases occupy a special place. More than the State guarantees of
protection of labor and security of tenure, labor disputes involve the
fundamental survival of the employees and their families, who depend -upon
the former for all the basic necessities in life.1

I.

RESPONDENTS’ CLAIM THAT

COMPLAINANT VOLUNTARILY
RESIGNED ON 20 FEBRUARY 2018 FINDS
NO BASIS IN FACT AND IN LAW.

1 Lorenzo T. Tangga-an vs Pidlippine Transmarine, et al, GR. No. 180636, 13 March 2013.
 2

Complainant did not

voluntarily resign, there
being no valid resignation
to speak of.

1.1 In their Position Paper, Respondents haplessly claimed

that Complainant’s verbal resignation on 20 February 2018 is
supported by substantial evidence.

1.2 In support of their position, Respondent cited the case of

FCA Security and General Services, Inc. vs Academia, Jr.2 and states that
the Supreme Court sustained the validity of the verbal resignation
because: a) The testimonies of other employees corroborated the employee’s
verbal resignation, b) the employee started to process his clearances, and c)
the employee failed to present evidence to dispute the credibility of the
witnesses against him.

1.3 From the very argument of the Respondents, it is clear

that one of the circumstances cited by the Supreme Court to sustain
the validity of a voluntary resignation is that the employee must have
started to process his clearances. This fact is very much absent in this
case as there is no showing and there is no proof that Complainant
has indeed taken any action whatsoever to start processing his
clearances.

1.4 While the Respondents claim that Complainant expressed

intent to process clearances, still without an overt act showing that he
actually went ahead and started his clearance procedure, it cannot be
said that the requirement that the employee must have started to process
his clearances is availing in this case.

1.5 More importantly, herein Complainant strongly reiterates

and maintains that HE DID NOT VOLUNTARILY RESIGN.

1.6 It must be noted that under the law and prevailing

jurisprudence, resignation is defined as "the voluntary act of
employees who are compelled by personal reasons to disassociate
themselves from their employment. It must be done with the
intention of relinquishing an office, accompanied by the act of
2 GR No. 189493, 2 August 2017.
 3

abandonment. The intent to relinquish must concur with the overt act
of relinquishment; hence, the acts of the employee before and after
the alleged resignation must be considered in determining whether
he in fact intended to terminate his employment.3 (Emphasis
supplied)

1.7 It is therefore imperative to consider the acts of the

Complainant before and after the alleged resignation.

1.8 Respondents admitted in paragraph 38 of their Position

Paper that on the same day that the alleged resignation happened,
Complainant asked for forgiveness and implored Respondents that
he be allowed to return to work.

1.9 In Annex “5” presented by the Respondents themselves,

it was stated by the Complainant that he merely got carried away and
overwhelmed by his emotions as in fact he said “Ma’am talagang
nabigla lng po tlaga aq pasensya na po kau.” (“Ma’am talagang nabigla
lang po talaga ako pasensya na po kayo.”) Complainant also asked if
he can talk to Sir Bernand (the owner) just so he can return to work,
and also begged HR Manager Hirang for another chance.

1.10 The acts of the Complainant after the alleged resignation,

coupled with the fact that Complainant did not take any overt act or
step to actually process his clearances (that could have signified his
intent to relinquish his position), negates that there had been
voluntary resignation on his part. Respondent even bolsters this
contention on paragraph 22 of their Position Paper. There it is stated,

“From 5:01PM to 5:08PM, complainant suddenly

changed his position and started making it appear
that he did not resign, contrary to his statement
during the meeting and his previous text
messages.”

1.11 From the foregoing, Complainant cannot overemphasize

that he did not only “made it appear that he did not resign”; in fact,
he did not voluntarily resign at all. This clearly shows that
Complainant’s subsequent acts negate that there was any intent to
resign, neither were there overt acts to that effect.

3 Zenaida D. Mendoza vs HMS Credit Corporation, et al, GR No. 187232, 17 April 2013.
 4

1.12 As to the testimony and affidavit of the HR Manager

Francia Hirang, supplemented by the statements of Mr. Mejia and
Ms. Pajotea, at its best, the supposed statements are merely self-
serving, having been executed by employees beholden to their
employer. Moreover, these statements failed to substantially establish
the validity of Complainant’s alleged resignation.

1.13 The statements of Ms. Hirang, Mr. Mejia and Ms. Pajotea
at most only narrate their version of what transpired during the
meeting and the supposed resignation of Complainant. It does not
serve to prove that there had really been a voluntary resignation, as
their testimonies are limited and no longer covers what transpired
after the meeting.

1.14 Another material point worth stressing is the general rule

that the filing of a complaint for illegal dismissal is inconsistent
with resignation. The Supreme Court in Shie Jie Corp. vs. National
Federation of Labor,4 held:

“By vigorously pursuing the litigation of his

action against petitioner, private respondent
clearly manifested that he has no intention of
relinquishing his employment which is,
wholly incompatible [with] petitioner[]s
assertion, that he voluntarily resigned.”

1.15 As further held in the case of Stanley Fine Furniture et. al.
vs. Victor T. Gallano and Enriquito Siarez,5 to wit:

”Long standing is the rule that the filing of the

complaint for illegal dismissal negates the
allegation of abandonment. Human
experience dictates that no employee in his
right mind would go through the trouble of
filing a case unless the employer had indeed
terminated the services of the employee.”

4 G.R. No. 153148, 15 July 2005.

5 G.R. No.190486, 26 November 2014.
 5

1.16 Obviously, herein Complainant initiated and filed a case

for illegal dismissal against the Respondents which is now pending
before this Honorable Office. This evidently negates the claims of
Respondents that there was voluntary resignation on Complainant’s
part.

1.17 If Complainant actually intended to relinquish and

abandon his position by way of voluntary resignation, then why is
there a need for him to ventilate this instant case for illegal dismissal
which entails stress, inconvenience and unnecessary expense on his
part; if not to seek justice for the unjust and unlawful acts committed
by the Respondents against him and his family by unlawfully
depriving him of his means of livelihood.

II.

COMPLAINANT WAS ILLEGALLY

DISMISSED WITHOUT ANY JUST CAUSE
AND WITHOUT BEING ACCORDED DUE
PROCESS UNDER THE PROVISIONS OF
THE LABOR CODE.

2.1 Having established that Complainant did not voluntarily

resign, there is no other logical conclusion aside from the fact that
Complainant was illegally terminated.

2.2 Complainant undoubtedly was a regular employee who

should have been afforded his right to security of tenure, a right
guaranteed by no less than the Constitution itself and by prevailing
labor laws.

2.3 As a regular employee, substantive due process provides

that Complainant may only be removed for any just or authorized
cause for dismissal.

2.4 To reiterate, the following are the just causes for dismissal
provided under the Labor Code:

“An employer may terminate an

employment for any of the following causes:
 6

(a) Serious misconduct or willful disobedience by

the employee of the lawful orders of his employer or
representative in connection with his work;

(b) Gross and habitual neglect by the employee of

his duties;

(c) 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 representatives; and

(e) Other causes analogous to the foregoing.”6

2.5 Meanwhile, the following are authorized causes for

dismissal:

(a) Installation of labor-saving devices.

(b) Redundancy.

(c) Retrenchment to prevent losses.

(d) Closure or cessation of operation.

(e) Disease.7

2.6 In the instant case, none of above-mentioned grounds are

availing. All that Respondents alleged was that during
Complainant’s tenure, he had been the subject of a disciplinary action
for unauthorized absences and subject of complaints from Ms.
Hirang and Mr. Mejia regarding company policies on taking leaves.
Nowhere in their Position Paper did Respondents establish that the
acts of the Complainant amounted to any of the just causes for
dismissal that could have constituted compliance with substantive
due process.

6 Art. 282, Labor Code of the Philippines.

7 Articles 283-284, Labor Code of the Philippines.
 7

2.7 Respondents also never alleged existence of any of the

authorized causes for dismissal. That being the case, it cannot be said
that substantive due process was met in the instant case.

2.8 Aside from substantive due process, it is equally well-

established that there must also be compliance with procedural due
process.

2.9 Generally, procedural due process requires that the

employer must furnish the employee with two written notices before
the termination of employment can be effected: (1) the first apprises
the employee of the particular acts or omissions for which his
dismissal is sought; and (2) the second informs the employee of the
employer's decision to dismiss him.8

2.10 In Unilever Philippines Inc. vs. Rivera,9 the Supreme Court

had the opportunity to discussed in detail the guidelines on how to
comply with procedural due process, to wit:

“1) The first written notice to be served on

the employees should contain the specific
causes or grounds for termination against
them, and a directive that the employees are
given the opportunity to submit their written
explanation within a reasonable period.
"Reasonable opportunity" under the Omnibus
Rules means every kind of assistance that
management must accord to the employees to
enable them to prepare adequately for their
defense. This should be construed as a period
of at least five (5) calendar days from receipt
of the notice to give the employees an
opportunity to study the accusation against
them, consult a union official or lawyer,
gather data and evidence, and decide on the
defenses they will raise against the complaint.
Moreover, in order to enable the employees to
intelligently prepare their explanation and
defenses, the notice should contain a detailed
narration of the facts and circumstances that

8 Distribution & Control Products Inc vs Santos, GR No. 212616, 10 July 2017.
9 G.R. No. 201701, 3 June 2013.
 8

will serve as basis for the charge against the

employees. A general description of the
charge will not suffice. Lastly, the notice
should specifically mention which company
rules, if any, are violated and/or which
among the grounds under Art. 282 is being
charged against the employees.

(2) After serving the first notice, the

employers should schedule and conduct
a hearing or conference wherein the
employees will be given the opportunity to:
(1) explain and clarify their defenses to the
charge against them; (2) present evidence in
support of their defenses; and (3) rebut the
evidence presented against them by the
management. During the hearing or
conference, the employees are given the
chance to defend themselves personally, with
the assistance of a representative or counsel of
their choice. Moreover, this conference or
hearing could be used by the parties as an
opportunity to come to an amicable
settlement.

(3) After determining that termination of

employment is justified, the employers shall
serve the employees a written notice of
termination indicating that: (1) all
circumstances involving the charge against
the employees have been considered; and (2)
grounds have been established to justify the
severance of their employment.”

2.11 In this case, no notice was ever given to the Complainant

that would at least show even a little semblance of compliance with
procedural due process. It must be noted that despite Complainant’s
right to security of tenure and despite his repeated pleas, Respondent
was told by HR Francia Hirang not to report for work anymore.
Worse, he was banned from returning to the company’s premises,
contrary to the claims of Respondents that Complainant was never
prohibited from reporting back to work.
 9

2.12 It was Complainant’s refusal to abide by a scheme being

offered by Respondent Company which he knew will greatly affect
his capability to provide for his family, that ultimately led to his
abrupt dismissal from employment. It is thus apparent that
Respondent is trying to circumvent the laws on security of tenure by
conveniently claiming that Complainant voluntarily resigned. In
truth, Complainant was told not to report back to work and was
illegally dismissed from employment.

2.13 Basic is the rule that in employee dismissal, the employer

carries the burden of justifying a dismissal. In this case, the
Respondents wants to take the easy way out by insisting that
Complainant voluntarily resigned even if such was not the case.

2.14 Respondents having failed to satisfactorily establish that

there was indeed any voluntary resignation to speak of; Complainant
must be deemed to have been illegally dismissed considering that
Respondents likewise miserably failed to prove its compliance with
the requirements of both substantive and procedural due process
under the Labor Code.

III

COMPLAINANT IS ENTITLED TO
PAYMENT OF BACKWAGES, AND
REINSTATEMENT OR IN LIEU THEREOF,
TO PAYMENT OF SEPARATION PAY

3.1 The law is clear that in cases of regular employment, the

employer shall not terminate the services of an employee except for a
just cause or when authorized by the Labor Code. An employee who
is unjustly dismissed from work shall be 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.10

3.2 As previously discussed, the Complainant did not

voluntarily resign and is deemed to have been a regular employee
illegally dismissed from employment. As a regular employee, he is

10 Art. 279, Labor Code of the Philippines.

 10

entitled to security of tenure and may only be properly terminated by

observing both substantive and procedural due process. However,
Respondents failed to prove that the Complainant was dismissed for
either a just or authorized cause. Neither was the Complainant given
the benefit of the twin requirements of notice and hearing. Not only
was the Complainant not apprised of his supposed acts and
omissions warranting dismissal, he was likewise not given any
opportunity to be heard. Instead, Respondent anchored heavily on
the alleged voluntary resignation of Complainant in order to
conveniently circumvent prevailing labor laws on security of tenure
and dismissal of employees.

3.3 Undoubtedly, the Complainant was unjustly dismissed

from employment considering that it was Respondent who explicitly
told him not to report back to work anymore. Also, it was
Respondents who prevented Complainant from reporting back
despite his efforts and pleas to return to work.

3.4 Hence, Complainant is entitled to reinstatement without

loss of seniority rights and other privileges and to his full backwages.

3.5 If in case reinstatement is no longer feasible, separation

pay in lieu of reinstatement is allowed and still subject to payment of
backwages.

3.6 To reiterate, the pertinent ruling in Aliling v. Feliciano,11

citing Golden Ace Builders v. Talde, provides as follows:

“Thus, an illegally dismissed employee is

entitled to two reliefs: backwages and
reinstatement. The two reliefs provided are
separate and distinct. In instances where
reinstatement is no longer feasible because of
strained relations between the employee and
the employer, separation pay is granted. In
effect, an illegally dismissed employee is
entitled to either reinstatement, if viable, or
separation pay if reinstatement is no longer
viable, and backwages.

11 G.R. No. 185829, 25 April 2012, 671 SCRA 186, 209.

 11

The normal consequences of (respondents')

illegal dismissal, then, are reinstatement
without loss of seniority rights, and payment
of backwages computed from the time
compensation was withheld up to the date of
actual reinstatement. Where reinstatement is
no longer viable as an option, separation pay
equivalent to one (1) month salary for every
year of service should be awarded as an
alternative. The payment of separation pay is
in addition to payment of backwages.”

3.7 As an illegally dismissed employee, Complainant 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. If the foregoing is no longer feasible, then
separation pay plus backwages may be awarded.

IV.

COMPLAINANT IS ENTITLED TO HIS

CLAIMS FOR MORAL DAMAGES,
EXEMPLARY DAMAGES AND
ATTORNEY’S FEES.

4.1 In labor cases, moral and exemplary damages are usually

awarded to employees wherein the termination of an employee was
indisputably tainted with bad faith and fraud, constituting an act
oppressive to labor, and was done in a manner contrary to morals,
good customs or public policy.12

4.2 In this case, the acts of the Respondents are evidently

tainted with bad faith and were done in a manner contrary to morals,
good customs or public policy. More importantly, the acts of the
Respondents all in all constitute acts oppressive to labor.

12Abbott Laboratories Philippines v. Alcaraz, G.R. No. 192571, 23 July 2013; Belaunzaran v.
National Labor Relations Commission, G.R. No. 120038, 23 December 1996.
 12

4.3 Foremost, Respondents did not observe the requirements

of both substantive and procedural due process in terminating the
Complainant. Respondents cowardly anchors heavily and solely on
the expedient and flimsy justification that Complainant voluntarily
resigned.

4.4 Note that Respondents themselves state that Complainant

has been the subject of a disciplinary action and of several complaints
from Respondent Francia Hirang. It is obvious from the Respondents
that they have issues with the Complainant as to his work habits and
attitude, and are unsatisfied with him overall (considering that
Respondents are the one who raise and stress the supposed
shortcomings and faults of the Complainant). However, instead of
observing the proper procedure to discipline Complainant or to
remove him from his position if truly warranted, Respondents
merely took a shortcut and persistently insisted on a supposed
resignation by Complainant, without any legal or factual bases.

4.5 As repeatedly raised over and over, Complainant

reflected on his actions and expressed that he did not actually desire
to resign from work. He made sure to let the Respondents know and
begged that he be allowed to return to work. Still, Respondents paid
him no mind and they did not allow Complainant to resume work.
There is no iota of good faith in the acts of the Respondents. In fact,
the acts of the Respondents in taking advantage of the situation by
insisting that Complainant voluntarily resigned just so they can
exempt themselves from complying with the proper termination
process loudly screams bad faith.

4.6 Cunningly, Respondents prevented Complainant from

returning to work and barred him from going in to the company
premises the next day after his alleged voluntary resignation. This
alone already constitutes as an act oppressive to labor. The Supreme
Court has held:

“The sudden and peremptory barring of the

concerned petitioners from work, and from
admission to the work place, after just a one-day
verbal notice, and for no valid cause bellows
oppression and utter disregard of the right to due
process of the concerned petitioners. Hence, an
 13

award of moral damages is called for.”13

(Emphasis supplied.)

4.7 Further, Article 2217 of the New Civil Code provides:

“Article 2217. Moral damages include physical

suffering, mental anguish, fright, serious anxiety,
besmirched reputation, wounded feelings, moral
shock, social humiliation, and similar injury.
Though incapable of pecuniary computation, moral
damages may be recovered if they are the
proximate result of the defendant's wrongful act
for omission.”

4.8 In the instant case, the family situation of the

Complainant was not unknown to the Company. The Respondents
knew that Complainant’s only source of income was his job as
Logistics Personnel for the Respondent Company. They also knew
that Complainant had a wife who was pregnant and had given birth
to twins and that Complainant was greatly in need of income in order
to support his family. Complainant repeatedly tried to seek the help
of the company regarding his dilemma. He pleaded with his
employer for aid and hoped that they can lend him a helping hand
when he needed it the most. However, instead of being a pillar of
support, the Company heartlessly left a father of three children with
no source of income and with no means to provide for his family. It
would be hard to imagine a world where these acts do not constitute
bad faith and oppressiveness to labor. Nor would sound standards of
morals, good customs or public policy ever consider or tolerate
Respondents acts as tolerable.

4.9 From the foregoing, it is clear that the award of moral

damages is justified.

4.10 As to exemplary damages, it is imposed by way of

example or correction for the public good. Exemplary damages are
imposed to serve as a deterrent against or as a negative incentive to
curb socially deleterious actions. In order to recover exemplary
damages, one must show that he is entitled to moral, temperate, or
compensatory damages.14

13 Aliviado et al vs Procter & Gamble Phils, GR No. 160506, 9 March 2010.

14 Del Rosario v. Court of Appeals, G.R. No. 118325, 29 January 1997.
 14

4.11 As exhaustively discussed, the Complainant is entitled to

the award of moral damages. In addition, exemplary damages must
be awarded in order to deter others from committing the same acts as
the Company.

4.12 The acts of the Company showing intent to circumvent

the law on security of tenure (a right that is constitutionally
protected) is a socially deleterious action that must not be emulated.

4.13 Additionally, the actions of the Respondents evince utter

disregard to the value of labor as a primary social economic force, as
their actions reflect no intent to protect and promote the rights of
workers, including herein Complainant.

4.14 As to the award of attorney’s fees, the case of Moreno v.

RTG Construction Inc. vs Facto15 must be reiterated as it was held
that,

“Settled is the rule that in actions for recovery of

wages, or where an employee was forced to litigate
and, thus, incur expenses to protect his rights and
interests, a monetary award by way of attorney's
fees is justifiable under Article 111 of the Labor
Code; Section 8, Rule VIII, Book III of its
Implementing Rules; and paragraph 7, Article
2208 of the Civil Code.” (Emphasis supplied)

4.15 Under both the Labor Code and Article 2208 of the Civil
Code, the mere fact that an employee was forced to litigate wherein
he incurred expenses to protect his rights and interests entitle him to
the award of attorney’s fees. Complainant’s entitlement to the award
of attorney’s fees is therefore unquestionable.

4.16 Overall, it would be at the height of social injustice not to

award the Complainant with his money claims. Justice dictates that
the acts of the Respondents must not be sanctioned for to rule
otherwise would lead to a blatant disregard of the Constitution and
the Labor laws.

15 GR No. 163872, Dec 21, 2009

 15

4.17 Since a finding of illegal dismissal is in order, the award

to the Complainant of moral and exemplary damages, as well as
attorney’s fees is both warranted and highly justified.

V.

COMPLAINANT HAS CAUSE OF ACTION

AGAINST HR MANAGER FRANCIA
HIRANG WHO CAN BE HELD
PERSONALLY LIABLE FOR
COMPLAINANT’S CLAIM.

5.1 Individual respondent Francia Hirang, in her personal

capacity, should be held solidarily liable with the Respondent
Company.

5.2 In a number of cases, the Supreme Court has held

corporate directors and officers are solidarily liable with the
corporation for the termination of employment of employees done
with malice or in bad faith.16

5.3 It must be stressed that individual respondent Hirang

was the one who told Complainant: ”Ronnel mag-resign ka na, umalis
ka na dito hindi na kita kailangan at hindi ka kawalan sa kumpanya.”

5.4 Aside from that, Respondent Hirang likewise was the one
who told Complainant “wag ka na pumasok” and ignored
Complainant’s pleas to be allowed to return to work.

5.5 As an officer of Respondent Company, instead of

preventing the injustice that befell the Complainant, individual
respondent acquiesced and condoned the illegal termination of
Complainant.

5.6 Also important to raise is the fact that despite knowledge

of the predicaments of Complainant regarding his family, individual
Respondent Hirang chose to ignore Complainant’s call for help even
though she could have done something, even little efforts, to aid

16Malayang Samahan ng mga Manggagawa sa M. Greenfield v. Ramos , G.R. No. 113907, 20 April
2001.
 16

Complainant. Individual respondent clearly acted with malice and in

bad faith, especially since she participated in dismissing Complainant
without just cause.

5.7 Thus, Complainant humbly submits that the individual

respondent must be held solidarily liable with respondent company
for the payment of complainant’s money claims.

VI.

POST SCRIPT

6.1 To summarize, the Respondents in this case would like to

make it appear that Complainant voluntarily resigned. However, the
discussions above negate this contention as the acts of the
Complainant, especially during after the alleged resignation, are
inconsistent with the claims of voluntary resignation.

6.2 The truth of the matter is that Complainant was illegally

dismissed without cause and the requirements of the law for a valid
termination was not complied with by the Respondents.

6.3 The termination of the Complainant was hinged solely on

the fact that he refused to avail of a motorcycle which was to be paid
on a salary-deduction basis, considering that his wife then had just
given birth to twins. Complainant would not be able to afford even
one cent deduction from his salary since he had a family to provide
for.

6.4 Instead of helping their own employee, Respondents

were the very people who banded together and deprived him of his
only source of income, at a time that was most crucial for
Complainant and his family. The acts of the Respondents
jeopardized the marriage of Complainant and his wife, and even
jeopardized the future of Complainant’s children.

6.5 The Respondents acted in bad faith, committed acts

which were not only oppressive to labor, but were also against
morals, good customs or public policy. The individual Respondent
Francia Hirang, condoned the wrongful acts of the Respondent
 17

Company and allowed for the law to be violated. Thus, they should
be solidarily liable to the Complainant for his money claims.

6.6 Lastly, having established that there was no voluntary

resignation; Complainant must be deemed to have been illegally
dismissed. That being the case, Complainant 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. Otherwise, if the foregoing is no longer feasible, then
payment of separation pay in lieu of reinstatement subject to
payment of backwages is in order.

RESPECTFULLY SUBMITTED.

Marikina City for Quezon City,

10 September 2018.

CHING & CHING LAW OFFICE

Counsel for the Complainant
No. 1 J. Chanyungco St.,
Brgy. Sta. Elena, Marikina City
Tel./Fax No. (02) 681-12-78

By:

VIRNALYN P. CHING
Roll of Attorneys No. 71304
PTR No. 7530142; 06-07-2018; Marikina City
IBP No. 039889; 05-08-2018; RSM
Admitted to the Bar – Year 2018

Copy furnished:

BRADY PHARMA INC.

3F Bendel Center, 281 EDSA,
Brgy. Highway Hills,
Mandaluyong, Metro Manila.


MCLE Governing Board Order No. 01, Series of 2008, 04 July 2008.