Republic of the Philippines

DEPARTMENT OF LABOR AND EMPLOYMENT

Regional Office XI
Davao City
-o0o-

IN RE: ROUTINE INSPECTION

CONDUCTED AT

DAIICHITOKYO SURPLUS CORPORATION CASE NO.

TANVEER MEHMOOD ROXI-03-RI-2019-11-034-G
Manager
Sinawilan, Digos City, Davao del Sur
Responding.
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COMPLIANCE WITH EXPLANATION

COMES NOW, Respondent DAIICHITOKYO SURPLUS CORPORATION,

represented by its manager TANVEER MEHMOOD assisted by counsel, and unto this
Honorable Office, most respectfully submits this Proposal and hereby avers that:

I am the sole proprietor of GPD CONSTRUCTION located at 2F Rural Bank of Digos

Bldg., Rizal Avenue, Zone 3, Digos City, Davao del Sur who caused the preparation of
this proposal;

2. That we received the copy of this Honorable Office’s Notice dated

October 9, 2020, pursuant to a Request for Assistance (RFA) filed by a certain
Wilma M. Larubes alleging her status an employee of GPD CONSTRUCTION;

3. For the record, Mrs. Wilma M. Larubes is not an employee of GPD

CONSTRUCTION. It is only her husband ZOSIMO C. LARUBES and his son
JASON M. LARUBES who are regularly employed with GPD CONSTRUCTION
for almost 20 years and 1 year, respectively;

4. Since being employees of GPD CONSTRUCTION as Grader Operators

at the Quarry site located at Kiagot, Digos City, Davao del Sur, they and their
family were allowed to live and stay in a house built and owned by the
undersigned since their employment;

5. Since Zosimo C. Larubes has been working in GPD for 20 years, the
undersigned have trusted him and his family to monitor the Quarry Site since they
lived within the site;

6. That since Wilma Larubes is a house wife and the caretaker of the house
they lived in; she often times volunteered or will be requested to collect sales in
some days from the quarry site and undertake to remit the income to GPD every
end of the day which she has an allowance of Php350.00 including meals during
that day.

7. However, it has come to the attention of the undersigned she has not
remitted certain amounts of the quarry sales thus prompting the undersigned to

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 conduct a deeper audit and thereafter called her attention at the Office of the
Barangay of Barangay Kiagot, Digos City, Davao del Sur (Attached herewith as
Annex “A” is a copy of their agreement);

8. After this agreement was signed, Mrs. Wilma never came back to their
house and not can’t be located;

9. Considering these events, we have no obligation to give any back wages

considering that Mrs. Wilma is not even an employee of GPD Construction. In
fact, she owes GPD Construction the amount of Php285,600.00 of
misappropriated cash sales from CPD Construction Quarry operations;

10. As to the benefits and other claims she requested, she is unqualified to
claim such benefits, if any, considering that she is not an employee of GPD
Construction and her aid to the Quarry Site is purely on trust and confidence of the
undersigned GENE PHILIP DEREQUITO with a concurrent allowance for the
efforts.

PRAYER
WHEREFORE, PREMISES CONSIDERED, it is most respectfully prayed by
Responding party of this Honorable Office that the instant Proposal be given due course
subject to existing rules and procedures.

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

RESPECTFULLY SUBMITTED on November 5, 2020 at Digos City For Davao

City, Philippines.

By:

GENE PHILIP DEREQUITO

Responding Party
Assisted by:

ATTY. CARLO MARTIN D. MARTEL

Roll of Attorney’s No. 67186
IBP No: 053608; 11/05/18
PTR No: 7672114; 01/3/19
MCLE Compliance No. VI-0009744 until 04/14/2022
WONG & MARTEL LAW OFFICES
2/F Rural Bank of Digos Bldg. (EDD Bldg.), Rizal Ave., Digos City
Contact No. 09189903909
Email add: mr.martin.martel@gmail.com

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