REPLY

Complainant, by herself, respectfully files this Reply to the Position Paper of the
respondents dated 26 February 2020 and states the following:

I.
COUNTER-STATEMENT OF FACTS

1. In paragraph 4 of respondents' position paper, they stated that I worked with the direct
employer from April 6, 2019 without any problem and attached a copy of my messages with
-------------. I do not deny that I did not experience any kind of cruelty or hardship during my
first two weeks with my direct employer. As I stated in my position paper, as soon as I was
transferred to the house of my direct employer's mother, my suffering began. I was required
to work from 7:00 in the morning until midnight for seven (7) days a week;

2. Assuming that my husband requested for my repatriation due to the maltreatment I

suffered, this does not negate the fact that I was constructively dismissed.

3. Lastly, I did not write the written manifestation (Annex 8), which they attached to
their position paper. In fact, they made me sign the same without fully explaining to me its
contents right before they brought me to the airport on October 27, 2019. It is considered a
waiver which was frowned upon by the courts.

II.
DISCUSSION

4. I was constructively dismissed when I was suddenly asked to pack my bags for
my flight back to the Philippines. This constitute dismissal. As there was no valid
ground for my dismissal, it should be deemed that I have been illegally dismissed.

5. Respondent violated the employment contract when the employer sent me home
before the expiration of my contract;

6. Thus, I am entitled to the unexpired portion of my contract, which amounts to 400

USD to be multiplied by seventeen months or the total amount of Six Thousand Eight
Hundred US Dollars (6,800 USD);

7. Respondents should also pay my unpaid salary for the month of June 2019.

PR AY E R

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

Honorable Office that after due consideration, a DECISION be rendered declaring the
complainant to be ILLEGALLY DISMISSED and the respondents to be liable for BREACH
OF CONTRACT and ordering the respondents to pay the complainant the following
amounts:

1
 a. Respondents should pay the complainant the unexpired portion of
her contract, which amounts to 400 USD to be multiplied by seventeen
months or the total amount of Six Thousand Eight Hundred US Dollars
(6,800 USD);

b. Respondents should also pay the complainant the amount of 300

Riyal for her salary for the month of JUNE 2019.

Other reliefs, just and equitable, are likewise prayed for.