REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF LABOR AND EMPLOYMENT

NATIONAL LABOR RELATIONS COMMISSION
NATIONAL CAPITAL REGION
PPSTA BLDG., BANAWE AVE., QUEZON CITY

MARIA CLARA K. IBARRA

Complainant,

-versus- NLRC NCR Case No. 01-52543-19

JUAN DELA CRUZ COMPUTER SERVICES

Respondent,
x----------------------------------------------------x

POSITION PAPER
(For the Respondent)

RESPONDENT Company, by counsel, most respectfully submits this Position Paper, for the
consideration of the Honorable Office, and states that:

PARTIES

Complainant MARIA CLARA K. IBARRA (Complainant, for brevity), is of legal age, single,
and a resident of Unit 9. Camelia Residence, Mandaluyong City.

Respondent JUAN DELA CRUZ COMPUTER SERVICES (Respondent for Brevity),

represented by its Corporate secretary Mr. Kevin R. Espinosa, is a corporation duly organized
under the requirements of the Philippine Laws, which holds its principal place of business at 6th
floor. Florentino Bldg., Pasig City.

The parties may be served with the notices, orders, and resolution of the Honorable Office in the
above-stated addresses.

STATEMENT OF FACTS

1. Respondent is a corporation engaged in, among other things, computer programming business,
wherein it processes an original formulation of computing problem to executable computer
programs.
Programming involves activities such as analysis, developing understanding, generating
algorithms, and verifications of requirements of algorithms including their correctness and
resources consumption, and implementation of algorithms in a target programming language.

2. On the other hand, complainant is an independent contractor, who possessed a unique skills
and talent in computer software. Her services were engaged to design, code, and modify
software, from layout to functions, of the respondent’s contract with clients.

3. That sometime in January 2019, respondent engages the herein complainant as its Software
Engineer to work on a specific project and undertaking, wherein the same was to be completed
for a period of five (5) months. A copy of the Project Employment Contract executed on January
2019 is hereto attached and made an integral part hereof as Annex “1”;

4. As stipulated on the said contract, the complainant is required to render her expertise in the
software computer exclusively for the herein respondent and/or the latter’s clients. It was also
stipulated that her compensation would be based on the development or completion of each of
the project done. However, the complainant would be bound by the respondent’s Rules and
Regulations, such as, the complainant will be required to report for work, although there is no
need for her to observe the regular working hours of the respondent, on the condition that she
would finish her tasked and project before the deadline comes;

5. It was also agreed that the herein complainant would not be included in the payroll of the
respondent and the complainant would be personally liable in paying her own contributions with
the Social Security Systems, PhilHealth, Pag-Ibig Contributions, and her personal income taxes.

6. The complainant, in pursuit of her contract with the respondent, would only use the certain
and the designated computer software and holographic machines to be provided exclusively by
the respondent. The complainant would independently do her job for the projects assigned to her,
however, each and every development of the project done by the complainant would be a subject
for approval by the respondent’s manager, wherein the latter is given full authority to revise,
reject, or accept the work done by the complainant.

7. On June 2019, the Project Employment Contract executed by the herein parties had been
terminated because of the completion of project. However, it was later on renewed because the
respondent took note of the good work done by the complainant, the reason the latter was given
another projects to work on. A copy of the 2nd, 3rd and 4th Project Employment Contracts dated
June 5, 2013, November 30, 2014, December 5, 2016, respectively, are hereto attached as
Annexes “2”, “3”, and “4”;

8. All things went well until the complainant was given her Fifth Project with the respondent
covered under their 5th Project Employment Contract. A Copy of the 5th Project Employment
Contract is hereto attached and made an integral part hereof as Annex “5”;

9. In the complainant’s fifth’s project, the respondent entrusted to the former their very important
foreign account and/or client. When the complainant was given the opportunity to work on the
same, she was given some strict specifications and was specifically instructed to use the software
and the special machine of the foreign account/client in finishing her work. Unfortunately, the
herein complainant deliberately violated the order and specifications, and instead used the
software and the machine of the respondent in finishing her 5th project.

10. As a result thereof, the foreign account/client was dissatisfied with the project, and for which
reason, it filed and sued the herein respondent allegedly for breach of contract and damages.

11. The complainant received a Notice to Explain sent to her by the herein respondent to explain
in writing within Five (5) days why he had not followed the specifications directed to him, which
caused irreparable work that she had done in his 5th project, and damage and injury to the
respondent. A copy of the Notice to Explain is hereto attached and made a part hereof as Annex
“8”;

12. Despite the opportunity given to the complainant, she did not comply nor file any written
explanation. The respondent was then constrained to send a Notice which terminates their 5th
Project Employment Contract. A Copy of the Notice of Termination is hereto attached and made
an integral part hereof as Annex “9”;

13. The herein complainant now filed this instant case and alleging that she was illegally
dismissed, and which claim is preposterous.

ISSUES

I. WHETHER OR NOT THERE IS AN EMPLOYER-EMPLOYEE

RELATIONSHIP;

II. WHETHER OR NOT COMPLAINANT MARIA CLARA K. IBARRA IS

CONSIDERED A REGULAR EMPLOYEE OF THE HEREIN RESPONDENT;

III. WHETHER OR NOT COMPLAINANT’S ACT IS EQUIVALENT TO

WILLFUL DISOBEDIENCE AS DEFINED UNDER JUST CAUSES OF
TERMINATION PURSUANT TO LABOR CODE.
 ARGUMENT AND DISCUSSION

I. WHETHER OR NOT THERE IS AN EMPLOYER-EMPLOYEE RELATIONSHIP

1. In determining the existence of an employer-employee relationship, the following elements or

the four-fold test are considered:
(1) the selection and engagement of the employee;
(2) the payment of wages;
(3) the power of dismissal; and
(4) Most determinative among these factors is the so-called "control test."

Of the above-mentioned elements, the right of control test is considered as the most important
element in determining the existence of employment relation. The control test initially found
application in the case of Viaña vs. Al-Lagadan and Piga, where the court held that there is an
employer-employee relationship when the person for whom the services are performed reserves
the right to control not only the end achieved but also the manner and means used to achieve that
end.
Control test thus refers to the employer’s power to control the employee’s conduct not only as
to the result of the work to be done but also with respect to the means and methods by which the
work is to be accomplished.
In applying this test, it is the existence of the right, and not the actual exercise thereof, that is
important.
In the instant case, there is no employer-employee relationship. The complainant would
independently do her programming skills for the projects assigned to her, however, each and
every development of the project done by the complainant would be a subject for approval by the
respondent’s manager.
However, the Court agrees with the disquisition of the REYES vs. GLAUCOMA RESEARCH
FOUNDATION, INC., G.R. No. 189255, June 17, 2015 on this matter, to wit:
[Respondents'] power to approve or reject the organizational plans drawn by
[complainant] cannot be the control contemplated in the "control test." It is but logical
that one who commissions another to do a piece of work should have the right to accept
or reject the product. The important factor to consider in the "control test" is still the
element of control over how the work itself is done, not just the end result thereof.
Well settled is the rule that where a person who works for another performs his job
more or less at his own pleasure, in the manner he sees fit, not subject to definite hours
or conditions of work, and is compensated according to the result of his efforts and not
the amount thereof, no employer-employee relationship exists.
xxx
As to the "control test", the following indubitably reveal that respondents wielded control over
the work performance of complainant, to wit: (1) that required him to work within the company
premises; (2) obliged complainant to report every day of the week and tasked him to usually
perform the same job; (3) they enforced the observance of definite hours of work; (4) the mode
of payment of complainant’s salary was paid in project basis; (5) they implemented company
rules and regulations; (6) that respondent directly paid complainant’s salaries and controlled all
aspects of his employment and (7) petitioner rendered work necessary and desirable in the
business of the company.
Aside from the control test, the Supreme Court has also used the economic reality test in
determining whether an employer-employee relationship exists between the parties. Under this
test, the economic realities prevailing within the activity or between the parties are examined,
taking into consideration the totality of circumstances surrounding the true nature of the
relationship between the parties. This is especially appropriate when, as in this case, there is no
written agreement or contract on which to base the relationship. In our jurisdiction, the
benchmark of economic reality in analyzing possible employment relationships for purposes of
applying the Labor Code ought to be the economic dependence of the worker on his employer.
There is likewise substantial evidence to support that Complainant MARIA CLARA K.
IBARRA was not an employee of JUAN DELA CRUZ COMPUTER SERVICES. Thus:
1. Complainant’s name does not appear in the list of employees reported with the Social Security
Systems, PhilHealth, Pag-Ibig Contributions, and personal income taxes.

2. Complainant’s name does not also appear in the payrolls of JUAN DELA CRUZ
COMPUTER SERVICES employees.

The Court does not agree with petitioner's insistence that her being hired as respondent
corporation's administrator and her designation as such in intra-company correspondence proves
that she is an employee of the corporation. The fact alone that complainant was designated as a
software engineer does not necessarily mean that she is an employee of respondents. Mere title
or designation in a corporation will not, by itself, determine the existence of an employer-
employee relationship. In this regard, even the identification card which was issued to petitioner
is not an adequate proof of complainant’s claim that she is respondents' employee. In addition,
complainant’s designation as a software engineer neither disproves respondents' contention that
she was engaged only as a graphic artist.
The NLRC did not gravely abuse its discretion in ruling that petitioner was respondent's regular
employee and, hence, was illegally dismissed by the latter. In this case, respondent disclaims any
liability for illegal dismissal, considering that, in the first place, no employer-employee
relationship existed between her and petitioner.
As a final point, it bears to reiterate that while the Constitution is committed to the policy of
social justice and the protection of the working class, it should not be supposed that every labor
dispute will be automatically decided in favor of labor. Management also has its rights which are
entitled to respect and enforcement in the interest of simple fair play. Out of its concern for the
less privileged in life, the Court has inclined, more often than not, toward the worker and upheld
his cause in his conflicts with the employer. Such favoritism, however, has not blinded the Court
to the rule that justice is in every case for the deserving, to be dispensed in the light of the
established facts and the applicable law and doctrine.
In the case of JESUS G. REYES vs. GLAUCOMA RESEARCH FOUNDATION, INC., EYE
REFERRAL CENTER and MANUEL B. AGULTO, G.R. No. 189255, June 17, 2015 the
Supre-me Court stated:
xxx
[Respondents'] power to approve or reject the organizational plans drawn by [petitioner]
cannot be the control contemplated in the "control test." It is but logical that one who
commissions another to do a piece of work should have the right to accept or reject the
product. The important factor to consider in the "control test" is still the element of
control over how the work itself is done, not just the end result thereof.
xxx
In the case of BERNARD A. TENAZAS, JAIME M. FRANCISCO and ISIDRO G.
ENDRACA vs. R. VILLEGAS TAXI TRANSPORT and ROMUALDO VILLEGAS the
Supreme Court stated:
"In this case, however, Francisco failed to present any proof substantial enough to
establish his relationship with the respondents. He failed to present documentary
evidence like attendance logbook, payroll, SSS record or any personnel file that could
somehow depict his status as an employee. Anent his claim that he was not issued with
employment records, he could have, at least, produced his social security records which
state his contributions, name and address of his employer, as his co-petitioner Tenazas
did. He could have also presented testimonial evidence showing the respondents’
exercise of control over the means and methods by which he undertakes his work. This
is imperative in light of the respondents’ denial of his employment and the claim of
another
taxi operator, Emmanuel Villegas (Emmanuel), that he was his employer. Specifically,
in his Affidavit, Emmanuel alleged that Francisco was employed as a spare driver in his
taxi garage from January 2006 to December 2006, a fact that the latter failed to deny or
question in any of the pleadings attached to the records of this case. The utter lack of
evidence is fatal to Francisco’s case especially in cases like his present predicament
when the law has been very lenient in not requiring any particular form of evidence or
manner of proving the presence of employer-employee relationship."
Moreover, On the criteria of the selection and engagement of the employee, complainant never
filed any application for employment with respondent. Complainant was not made to undergo
any examination and interview to be conducted by the respondent before she was finally hired.
For the payment of the wages of the complainant, it was stipulated that her compensation would
be based on the development or completion of each of the project done. The payroll and pay
records did not include the name of complainant and she was not given the usual pay-slip to
show his monthly gross compensation; neither has the respondent withheld his taxes nor was she
enrolled as an employee of the respondent under the Social Security System Pag-ibig and
Philhealth.
As regards the criteria of the power to dismiss, respondent is not in the position to dismiss or
sanction complainant in whatever manner because she is not its regular employee.
With respect to the criteria of the power of control, respondent does not exercise the power of
control over complainant as to the means and method with which to accomplish their work.
There is no need for the complainant to observe the regular working hours of the respondent,
provided she would finish her tasked and project before the deadline comes.
In the case of SSS vs. Court of Appeals, 30 SCRA 210 [1969] the court ruled that:
“Where the element of control is absent; where a person who works for another does so
more or less at his/her own pleasure and is not subject to definite hours or conditions of
work, and in turn is compensated according to the result of his effort, the relationship of
employer-employee does not exist.”

II. WHETHER OR NOT COMPLAINANT MARIA CLARA K. IBARRA IS

CONSIDERED A REGULAR EMPLOYEE OF THE HEREIN RESPONDENT;

1. Complainant MARIA CLARA K. IBARRA is NOT a regular employee of the respondent.

She is a project employee.

Article 294 of the Labor Code, as amended, distinguishes a project-based employee from a
regular employee as follows:
x x x.
“Article 280. Regular and Casual Employment.—the provisions of written agreement
to the contrary notwithstanding and regardless of the oral agreement of the parties, an
employment shall be deemed to be regular where the employee has been engaged to
perform activities which are usually necessary or desirable in the usual business and
trade of the employer, except where the employment has been fixed for a specific
project or undertaking, the completion or termination of which has been determined at
the time of the engagement of the employee or where the work or services to be
performed is seasonal in nature and the employment is for the duration of the season.
An employment shall be deemed to be casual if it is not covered by the preceding
paragraph: Provided, That, any employee who has rendered at least one year of service,
whether such service is continuous or broken, shall be considered a regular employee
with respect to the activity in which he is employed and his employment shall continue
while such activity exists.
x x x.
In the case of OMNI HAULING SERVICES –versus-BON, G.R. No. 199388, September 3,
2014, the Court extensively discussed how to determine whether an employee may be properly
deemed project-based or regular, to wit:
x x x.
“A project employee is assigned to a project which begins and ends at determined or
determinable times. Unlike regular employees who may only be dismissed for just
and/or authorized causes under the Labor Code, the services of employees who are
hired as project-based employees, may be lawfully terminated at the completions of the
project.”
 x x x.
According to jurisprudence, the principal test for determining whether particular employees are
properly characterized as “project employees” as distinguished from “regular employees”, is
whether or not employees were assigned to carry out a “Specific project or undertaking, the
duration and scope of which were specified at the time they were engaged for that project. The
project could either be (1.) a particular job or undertaking that is within the regular or usual
business of the employer company, but which is distinct and separate, and identifiable as such,
from the other undertakings of the company; or (2.) a particular job or undertaking that is not
within the regular business of the corporation. In order to safeguard the rights of workers against
the arbitrary use of the word “project” to prevent employees from attaining a regular status,
employers claiming that their workers are project-based employees should not only prove that
the duration and scope of the employment was specified at the time they were engaged, but also,
that there was indeed a project.
Verily, for an employee to be considered project-based, the employer must show compliance
with two (2) requisites, namely that: (a.) the employee was assigned to carry out a specific
project or undertaking; and (b.) the duration and scope of which were specified at the time they
were engaged for such project.
In the instant case, there are so much evidence to show that the herein respondent had adequately
informed the herein complainant of her employment status at the time of her engagement, as
evidenced by the 1st , 2nd, 3rd, and 4th, Project Employment Contracts and herein marked and
made an integral part hereof as Annexes “1”, “2”, “3”, and “4”, respectively.
Also, the complainant was adequately informed of her employment status at the time of her
engagement in the 5th project, as evidenced by the former’s 5th Project Employment Contract,
marked and hereto attached as Annex “5”, which provide that the complainant was hired in
connection with the respondent’s very important Foreign Account/Client, and that her position as
a software was a “project-based” and as such is co-terminus to the project.
Also in this instant case, the herein respondent had substantially complied with the requisite
when it expressly indicated in the complainant’s 5th Project Employment Contract that her
position is co-terminus with the project.
On this score, it can ruled that the herein complainant was indeed a project-based employee and
not a regular employee, considering that she was hired only to carry out a specific undertaking,
i.e. the 5th Project; and the duration and scope of such project was made known to her at the time
of his engagement, i.e. co-terminus with the project.
Further, the work done by the herein complainant is not necessary and indispensable in the line
of work or operation of the respondent company.
It should be emphasized that the respondent company is a computer programming company,
which is primarily and limited only in making an original formulation of computing problem to
executable computer programs. On the other hand, the herein complainant who is an independent
contractor and who possesses a unique skills and talent in graphic arts, was only engaged when
the respondent’s client would request for an artistic product or service. It should be noted that not
all of the respondent’s clients would avail of the services of the complainant, the reason that
every time that the respondent would have a client that would request for an artistic product, the
same was being contracted out by the herein complainant.
Furthermore, although the herein complainant had been contracting with the respondent for more
than a year, when in fact, for five (5) years, her status as a project employee remains unchanged.
In the case of Judy Dacuital, et.al. vs. L.M. Camus Engineering Corp., G.R. No. 176748,
September 1, 2010, the Supreme Court held:
x x x.
“A project employee is assigned to a project which begins and ends at determined or
determinable times. Employees who work under different project employment contracts
for several years DO NOT automatically become regular employees; they can remain as
project employees regardless of the number of years they work. Length of service is not
a controlling factor in determining the nature of one’s employment. Their rehiring is
only a natural consequence of the fact that experienced construction workers are
preferred. In fact, employees who are members of a work pool from which a company
draws workers for deployment to its different projects do not become regular employees
 by reason of that fact alone. The Court has consistently held that members of a work
pool can either be project employees or regular employee.”
x x x.
In the instant case, there is an evidence that will show that herein parties in this case had entered
into a project employment agreement as evidenced by herein attached Annexes “1” to “5”. The
said Agreements well informed the complainant of its nature and duration. Further, each and
every expiration of the said Project Agreements, the herein respondent was religiously reporting
the said fact to the Public Employment Office, pursuant to Department Order No. 19. A Copy of
the Certification issued by Public Employment Office is hereto attached and made an integral
part hereof as Annex “6”.
Since the complainant is now determined to be a project-based employee, there is no ground then
for her to claim that she was illegally dismissed as the contract of the herein respondent with the
foreign client in the 5th project was already been terminated. A copy of the Termination of
Project Agreement Letter issued by the respondent’ very important foreign account is hereto
attached and made an integral part hereof as Annex “7”;

III. WHETHER OR NOT COMPLAINANT’S ACT IS EQUIVALENT TO WILLFUL

DISOBEDIENCE AS DEFINED UNDER JUST CAUSES OF TERMINATION
PURSUANT TO LABOR CODE.

1. Complainant’s act is equivalent to WILLFUL DISOBEDIENCE as defined under just

causes of termination pursuant to labor code.
Just Causes for dismissal of employee may be defined as those lawful or valid grounds for
termination of employment which arise from causes directly attributable to the fault or
negligence of the erring employee. Just cause is usually serious or grave in nature and attended
by willful or wrongful intent or they reflected adversely on the moral character of the employees.
Just causes and authorized causes. -As mentioned in Article 279, there are two (2) kinds of
causes or grounds to terminate employment by employer, to wit:
 1. “Just causes” which refer to those instances enumerated under Article 282 [Termination
by employer] of the Labor Code.

 2. “Authorized causes” which refer to those instances enumerated under Articles 283
[Closure of establishment and reduction of personnel] and 284 [Disease as ground for
termination] of the Labor Code.

Under Article 283, wilful disobedience to lawful orders is that the employees are bound to
follow reasonable and lawful orders of the employer which are in connection with their work.
Failure to do so may be ground for dismissal or other disciplinary action.
In the case of Billy M. Realda vs. New AGE Graphics Inc and Julian L. Mirasol, Jr., G.R. No.
192190, April 25, 2012 Supreme Court held:
x x x.
"Willful disobedience requires the concurrence of at least two requisites: (1) the
employees assailed conduct must have been willful or intentional, the willingness being
characterized by a wrongful and perverse attitude; and (2) the order violated must have
been reasonable, lawful, made known to the employee and must pertain to the duties
which he had been engaged to discharge."
x x x.
In the instant case, there are so much evidence to show that the herein complainant intentionally
violated the order and specifications. In the complainant’s fifth’s project, the respondent
entrusted to the former their very important foreign account and/or client. When the complainant
was given the opportunity to work on the same, she was given some strict specifications and was
specifically instructed to use the software and the special machine of the foreign account/client in
finishing her work. Unfortunately, the herein complainant deliberately violated the order and
specifications, and instead used the software and the machine of the respondent in finishing her
5th project.
As a result thereof, the foreign account/client was dissatisfied with the project, and for which
reason, it filed herein respondent for breach of contract because of willful disobedience of the
petitioner.
In Manebo vs. NLRC, G.R. No. 107721, January 10, 1994, the court reiterated that in order that
an employer may terminate an employee on the ground of willful disobedience to the employee’s
orders, regulations or instructions, it must be established that the said orders, regulations or
instructions are:
 1.) reasonable and lawful;
 2.) sufficiently known to the employer; and
 3.) in connection with the duties which the employee has been engaged to discharge.

Further, the termination of an employee was reasonable and lawful. As stipulated on the said
contract, the complainant is required to render her expertise in the software and was given some
strict specifications and was specifically instructed to use the software and the special machine of
the foreign account/client. However, complainant herein used the software and machine of the
respondent. Therefore, respondent has the adequate reason and lawful to terminate the
complainant.
In the case of Nathaniel N. Dongdon vs. Rapid Movers and Forwarders Co., INC., and/or
Nicanor E. Jao, Jr., G.R. No. 163431, August 28, 2013 cited:
Article 282 of the Labor Code provides:
'Termination by Employer -An employee may terminate an employment for any of the
following causes:
 (a) Serious misconduct or willful disobedience by the employee of the lawfull orders
of his employer or representative in connection with his/her work;

x x x.
The constitutional protection afforded to labor does not condone wrongdoing by the
employee; and an employer's power to discipline its workers is inherent to it. As
honesty is always the best policy, the court is convinced that the ruling of the Labor
Arbiter is more in accord with the spirit of the Labor Code. "The Constitutional policy
of providing full protection to labor is not intended to oppress or destroy management
(Capili vs. NLRC, 270 SCRA 488[1997]."Also, in Atlas Fertilizer Corporation v.
NLRC, 273 CSRA 549 [1997], the Highest Magistrate declared that "The law in
protecting the rights of the laborer’s, authorizes neither oppression nor self-destruction
of the employer."
x x x.

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable
Tribunal, that judgment be rendered, by DISMISSING the instant case for lack of merit to wit:
That herein Complainant MARIA CLARA K. IBARRA is Not considered a regular employee
of the herein respondent, hence, a Project Employee.
Furthermore, just causes of termination of the Complainant pursuant to labor code was complied
with.
The judgment be issued declaring that the Complainant has been LEGALLY DISMISSED by
herein Respondent.
Other reliefs that are just and equitable are likewise prayed for.
May 21, 2021, Quezon City.
 ATTY. JUAN DELA CRUZ
Counsel for the Respondent
th
6 floor. Florentino Bldg., Pasig City
Roll No.
IBP No.
MCLE Compliance No.

Copy Furnished:
ATTY. PEDRO BAUTISTA
Counsel for the Complainant
19TH floor. Florida Bldg., Pasig City
 VERIFICATION AND CERTIFICATION

I Mr. Kevin R. Espinosa, a representative of JUAN DELA CRUZ COMPUTER SERVICES

with the principal office at 6th floor. Florentino Bldg., Pasig City, after having been duly sworn
to in accordance with the law, depose and state that:

1. That I am the President and the authorized representative of the respondent company in
the above-entitled case;

2. That I have caused the preparation of the foregoing Position Paper;

3. I have caused the preparation of the complaint, the contents of which are true and correct,
of my personal knowledge, and based on the authentic records;

4. I further certify that I have no commenced any other action or proceeding involving the
same issued in the Supreme Court, Court of Appeals, or different Division thereof, or any
other tribunal or agency;

5. If I should learn that a similar action or proceeding has been filed or pending before the
Supreme Court, Court of Appeals, or different Division thereof, or any other tribunal or
agency, I hereby undertake to notify this Honorable Office within (5) days from such
notice.

IN WITNESS WHEREOF, I have affixed my signature this May 21, 2022 in Pasig City,
Philippines.

Kevin R. Espinosa
Affiant

SUBSCRIBED AND SWORN before me this May 21, 2022 in Pasig City, Philippines.

ATTY. JUAN DELA CRUZ

Counsel for the Respondent
6th floor. Florentino Bldg., Pasig City
Roll No.
IBP No.
MCLE Compliance No.