Republic of the Philippines

NATIONAL LABOR RELATIONS COMMISSION

Regional Arbitration Branch No. ______
[CITY]

_____________________,
Complainant,
NLRC ____ Case No.___________

-versus-

_____________________,

Respondent,
x---------------------x

REPLY TO POSITION PAPER OF COMPLAINANT

RESPONDENT, by the undersigned counsel and unto this Honorable Office, most
respectfully submits this Reply to Complainant’s Position Paper and avers the following:

I.
[Discussion of the issue or fact raised in the position paper that is sought to be contested.
provide rebuttal arguments with your legal basis]

II.
[Discussion of the issue or fact raised in the position paper that is sought to be contested.
provide rebuttal arguments with your legal basis]

III.
[Discussion of the issue or fact raised in the position paper that is sought to be contested.
provide rebuttal arguments with your legal basis]

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this Honorable

Office that the complaint for ________________ be DENIED and that respondent’s
counterclaims for [damages and attorney’s fees] be GRANTED.

Other reliefs just and equitable under the premises are also prayed for.

RESPECTFULLY SUBMITTED.

[CITY] ___________; [DATE] _________________________.

[SIGNATURE]
[NAME OF COUNSEL] ___________
Counsel for [RESPONDENT]
[ADDRESS] ______________
IBP Lifetime No. ____________; [CITY] _____________
PTR No. _______________; [DATE], [CITY]
Roll of Attorney No. _______________________
MCLE Compliance No. ____________________
Copy furnished through personal service:

[NAME OF COUNSEL] __________________

Counsel for the [COMPLAINANT]
[FIRM NAME] _______________
[ADDRESS] ________________

[USE THE FOLLOWING IF SERVICE IS NOT MADE PERSONALLY]

Copy furnished through registered mail:

[NAME OF COUNSEL] __________________
Counsel for the [COMPLAINANT]
[FIRM NAME] _______________
[ADDRESS] ________________
Registry Receipt No. ________
Post Office ________________
Date _____________________

EXPLANATION

The foregoing [REPLY TO POSITION PAPER] _______________and its attachment were

served on [NAME OF COUNSEL] ________________ by registered mail instead of personal
service as counsel for [PLAINTIFF/DEFENDANT] [STATE REASON] ___________________.

[SIGNATURE]
[NAME] _________________

VERIFICATION

Republic of the Philippines )

City of _______________ ) s.s.

RESPONDENT, after having been duly sworn in accordance with law, deposes and
states that:

1. He is the respondent in the pleading/document entitled _____________________

2. He has caused its preparation
3. He has read it and the allegations therein are true and correct of his own
knowledge or based on authentic records.

[SIGNATURE]
[NAME] _________________

SUBSCRIBED AND SWORN TO before me in the City of _______________ on this day

of [MONTH AND YEAR]_________________, affiant exhibiting before me his Government
Issued ID no. _______________ issued on [DATE}__________________ at [PLACE OF
ISSUANCE]_____________________.

[SIGNATURE]
[NAME]_______
Notary Public
Until [DATE]__________________
PTR No. [NUMBER] ____________
Issued at [PLACE]______________
On [DATE] ___________________

Doc. No. _______;

Page No. _______;
Book No. ______;
Series of 20_____.