Republic of the Philippines

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION
National Capital Region Arbitration Branch
Quezon City

JESUS T SOCORRO,
Complainant, NLRC-RAB Case No.
NCR-07-11054-11

- versus -
Hon. Labor Arbiter
ROMELITA N RIOFLORIDO

UNISPORT MARKETING CORP., JOSE

YU, ELEANOR YU OCAMPO,
Respondents.
x ---------------------------------------------x

POSITION PAPER

COMPLAINANT, through the undersigned counsels and to this Honorable Office, most
respectfully submits this Position Paper –

PREFATORY STATEMENT

When a person has no property, his job may possibly be his ONLY possession or means of
livelihood and those of his dependents.

When a person loses his job, his dependents suffer as well. The worker should therefore, be
protected and insulated against any arbitrary deprivation of his job 1.

The esteemed educator, economist, author and dedicated freemason Dean Conrado F. Benitez,
always reminded his brother masons that:

“One of the five cardinal principles of our Constitution is the promotion of social
justice ‘to insure the well-being and economic security of all the people’ which ‘should
be the concern of the State’. But Social Justice should not be the concern of the State
1
Philips Semiconductors [Phils.], Inc v Fradiquela, G.R. No 141717, April 14, 2004.
 alone. It should be the concern of all successful citizens whose success is possible only
in a free society that enables them to succeed according to their individual merit and
initiative. Hence, the Christian and democratic duty of giving and sharing, for verily, “ it
is more blessed to give than to receive”.2

Unfortunately, nowadays this exhortation finds application more in its violation than in its
observance especially in the treatment by the employer of his worker. Hence, in case of severance from
employment, the poor laborer has no one else to turn to but the State alone.

This call for aid is brought to fore once again in the instant complaint. A hapless employee who,
after spending the best years of his life with the same employer was constructively dismissed from
employment through a series of discriminatory and oppressive acts.

ACTION

This is a complaint for illegal constructive dismissal with claim for payment of backwages, moral
and exemplary damages, unpaid commissions, separation pay and attorney’s fees.

THE PARTIES

2
underscoring and emphasis supplied; Sovereign Grand Commander’s Message (MW
Conrado Benitez, PGM), Christmas Thoughts, Far Eastern Freemason, from the
compilation, Reynold S. Fajardo, Conrado Benitez, the Mason, p. 209.