REPLY

(To Respondents' Position Paper dated 3 rd September 2020)

COMPLAINANT, by counsel, to this Honorable Office, by way of Reply to

respondents' Position Paper dated 3rd September 2020, most respectfully sets forth the
following:

1. Complainant denies the allegation of the Respondents’ Position Paper in

paragraph 5 that complainant’s monthly salary is P14,046.00 when he only
receives P10,000 as his monthly salary since he became a shop man for
respondent ABC.

2. Complainant also denies the allegation of Respondents Position paper in

paragraph 6 that he voluntarily resigned from his work. Complainant denies
the alleged handwritten resignation later which allegedly stated his
resignation due to the desire to return to the province with his family upon
request by his sick mother, apart from the need to attend to their farm and
his intention to take a much needed rest. There is no handwritten resignation
letter given by Complainant to Respondent.

3. Complainant also denies the allegation of Respondents’ Position Paper in

paragraph 6 that he never reported for work and could no longer be located
when in truth and in fact, after he took his leave of absence as he needs to
go to the province, he was not allowed by Respondent to return back and
report for work.

4. Complainant also denies the allegation of Respondents’ Position Paper in

paragraph 7 that stated that he resigned from work because he wants to
receive a separation pay to use in settling and paying his numerous
obligations. Complainant denies that he resigned from work and that he
was constructively dismissed when he was not allowed to go bak and
report for work after his leave of absence