October 20, 2010

ABC Inc.
G/F ABC Plaza Building
Sen. Gil Puyat Avenue corner Tordesillas Street
Makati City

Attention: Mr. DEF

Vice President for Operations

Gentlemen:

We write on behalf of our client, Ms. XYZ, whose employment in your

company had been unjustly terminated on October 14, 2010.

Please be reminded that the Labor Code and our jurisprudence are explicit
on the grounds upon which an employer may terminate the services of his
employee – i.e. that the ground must be of such a grave and aggravated character,
and must have been committed willfully, voluntarily and with malicious intent as
to warrant the dismissal or termination of employment. The allegation of
misconduct you had made against our client, and which you used as a ground for
her termination, falls far below the degree required by law.

Further, it has come to our knowledge that your company had a recent
change in management is now retrenching/terminating employees as a result
thereof. Thus, we have basis to believe that your unjust termination of the
services of Ms. XYZ is merely a convenient excuse on your part to evade the
payment of her separation pay. This conclusion has become more apparent after
learning from our client that Ms. Z, the employee who had actually accomplished
the alleged false sign-off sheet, was never meted any disciplinary action nor even
any investigation as regards her conduct.

Ms. XYZ has dedicated eleven (11) long years rendering service to your
company. Throughout her employment, her performance rating had never gone
below a more than satisfactory rating. There were even occasions when her
ratings had reached the level of a perfect 4% (based on your company’s rating
standards).

In view of the foregoing, demand is hereby made upon you to pay our
client, within five (5) days from receipt of this letter, the separation benefits to
which she is entitled as a result of your unjust termination of her services.
Demand is likewise made upon you to pay our client the cash equivalent of her
accumulated Sick and Vacation Leaves and pro-rated 13th Month Pay. Finally,
demand is made upon you to issue an honorable dismissal to our client.
 Should you wish to discuss this matter with us, please let us know so we
can set a meeting for the purpose.

Very truly yours,