Republic of the Philippines

CIVIL SERVICE COMMISSION

___________________ Region
____________ City

MR NAME EMPLOYEE,
Complainant,
-versus- Case No. _____________

NAME OF OFFICER
GOVERNMENT POSITION,
Respondents.
x-------------------------------------------x

ADMINISTRATIVE COMPLAINT

COMPLAINANT, to this Honorable Office, most respectfully

submit this position paper in support of the Complaint as follows:

PREFATORY STATEMENT

“The BILL OF RIGHTS under Section 1.,

ARTICLE 3 of the Constitution provides; No person
shall be deprived of life, liberty, or property without due
process of law, nor shall any person be denied the equal
protection of the laws. “

“It is a principle in American jurisprudence which,

undoubtedly, is well-recognized in this jurisdiction that
one’s employment, profession, trade or calling is a
property right, and the wrongful interference therewith is
an actionable wrong. The right is considered to be
property within the protection of a constitutional
guaranty of due process of law. (TEEKAY SHIPPING
PHILS., INC., and/or TEEKAY SHIPPING CANADA,
versus RAMIER C. CONCHA, G.R. No. 185463. 22
February 2012.).

“It is no less than the Constitution which guarantees

protection to the workers’ security of tenure as a policy
of the State. This guarantee is an act of social justice.
(ANTONIO M. SERRANO, petitioner, versus
GALLANT MARITIME SERVICES, INC. AND
MARLOW NAVIGATION CO., INC., respondents.,
G.R. No. 167614, 11 November 2004.).

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 STATEMENT OF THE CASE

This is an Administrative Complaint filed against the respondent for

violating the Constitutional, Legal and Human Rights of the Complainant
Government Employee.

Complainant avers, (Please state how your rights were violated in this
portion), that violates the right of the complainant to life, liberty, property
and privacy as provided under the Bill of Rights.

THE PARTIES

Complainant, NAME OF EMPLOYEE of legal age, Filipino, resident of

ADRESS OF COMPLAINANT, and a regular government employee,
under the law, of herein Complainant.

Respondent, NAME., is DESIGNATION AND OFFICE, under the

Republic of the Philippines with official address at ADRESS OF
GOVERNMENT OFFICIAL.

FACTS OF THE CASE

Complainant NAME OF EMPLOYEE PEREZ was hired by respondents

on JAN 1, 2021 as a POSITION/DESIGNATION and is a Regular
Employee under the Government Office.

As proof and pieces of evidence, complainant hereto attaches and make

integral part hereof copies of the Appointment Papers marked as Annex
“A”, a copy of the Certificate of Employment as Annex “B”, Payslips “C”.

The circumstances surrounding the Administrative Complaint of herein

Complainant was clearly established and narrated in detail below.

(PLEASE STATE ALL THE DETAILS, EVENTS,

PERSONS CONCERNED, DATES AND OTHER
CIRCUMSTANCES, SIMILAR TO AN AFFIDAVIT
IN THIS PORTION)

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 NAME AND SIGNATURE AFFIANT
GOVERNMENT ID XXXX NO.XXXXX

VERIFICATION AND CERTIFICATION ON NON-

FORUM SHOPPING
I, NAME OF EMPLOYEE, of legal age, Filipino, after being
duly sworn, depose and say:

1. That I am the complainant in the above-entitled case; I have caused the

preparation and filing of the foregoing Position Paper; I have read the
contents of the same; and that I affirm as true and correct the allegations
contained therein, to the best of my own personal knowledge or based on
authentic records;

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2. That I have not commenced any other action or filed any
claim involving the same issues in any court, tribunal or quasi-judicial
agency and that to the best of my own knowledge, no such other action or
claim is pending in any court, tribunal or quasi-judicial agency;

3. That if I should thereafter learn that a same or similar action or claim has
been filed or pending before any court, tribunal or quasi-judicial agency, I
will undertake to report such fact within five (5) days therefrom to the court,
tribunal or quasi-judicial agency wherein the aforesaid complaint or
initiatory pleading has been filed.

IN WITNESS WHEREOF, I hereunto affixed my signature this

_____th day of __________ 2022 here in ___________ City.

Name and Signature of Complainant/Affiant

Government Issued ID:

SUBSCRIBED AND SWORN to before me this _______th day

____________2022 here in _____________City. Affiant exhibited to me
his/her respective government issued I.D. with numbers indicated above to
prove and establish his/her personal identity.

Doc. No. _____;

Page No. _____;
Book No. _____;
Series of 2022.