1

Republic of the Philippines

Department of Labor and Employment
NATIONAL LABOR RELATIONS COMMISSION
Quezon City

SUSANO BAGALLON ROJALES, ET. AL.,

Complainants,

NLRC CASE NO. NCR -03-01104-03

vs HON. JONALYN M. GUTIERREZ

COCA-COLA BEVERAGE PHILS.

INC, ET. AL.,
Respondents.
x--------------------------------------------------------x

RESPONDENT B-MIRK REPLY AND COMMENTS

ON THE COMPLAINANTS’ POSITION PAPER

Respondent B-MIRK ENTERPRISES CORPORATION (B-Mirk, for

brevity), through its authorized representative RAMON A. CASTRO,
before this Honorable Office, most respectfully submit this REPLY,
and similarly argues, THAT:

1. Complainants’ case against the respondents which are shown

under the Statement of Facts of their submitted Position Paper
merely enumerated their claim for:

 REGULARIZATION WITH COCA-COLA BEVERAGES,

PHILS., INC. (COCA – COLA, FOR BREVITY)
 MONEY CLAIMS, BENEFITS, AND PRIVILEGES BEING
ENJOYED BY REGULAR COCA-COLA REGULAR
EMPLOYEES.
 SALARY DIFFERENTIALS
 DAMAGES AND ATTORNEY’S FEE

2. In the above paragraph, complainants mentioned that their

cause of action aside from regularization includes CBA Wage &
benefits, differentials, and underpayment of wages, attorneys’
fees, moral and exemplary damages. However, herein humble
respondent expresses vehement act of negation on all the
complainants’ claims arguing that the latter could not qualify
to avail those things considering that they are being B-Mirk’s
regular employees and being not Coca Cola Employees are not
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rightful to claim those mentioned. Only those employees of

Coca cola Employees can avail of such CBA Benefits.

3. It is further contended that COMPLAINANTS have no basis for

claiming CBA Benefits. As gleaned from the records, it is worth
stressing that complainants did not even care to prove nor
substantiate that they are members of the unions. Their mere
claim that they are union members is significantly stranger
than they are, indeed, members of the same. The two are
completely different because in the allegation or claim
asserting as members, it necessitates a document confirming
the same and not a just mere claim or presentation of
allegation. While they were the one alleging the same, the unos
provandum also rests on their burden. This is in consonance
with the rule that “he who alleges not who denies must
prove. Failure to adduce is logical to infer that complainants
must not be entitled to CBA Benefits. Where there is absence
of any proof of the same, it therefore follows that the
complainants’ contention has committed a serious mistake
and that they should be able to avail of CBA Benefits. That
they cannot positively sustain their claim according to the
merit of evidence. This is an elementary and fundamental
principle under the rule as to the burden of proof.

4. Considering that complainants have not adduced any proof to

substantiate their established membership with the union as
above explained and argued, it follows that they have no
accredited personality to claim for the benefits be accorded to
members thereof, and since the Complainants have already
had been paid based on DOLE Mandated Wage, there is no
reason that they will be paid again.

5. And as to their claim on Attorney’s Fees, and Moral and

Exemplary Damages, the same are baseless, and that there is
no basis that respondents be paid for the same. Where there is
no injury made by the respondents upon them, and that there
is no act of breach committed against them, hence there is no
reason that they will be compensated on their claim for moral
and exemplary damages considering it to be baseless, and
unfounded.

6. In the case of G.R. No. 142029 February 28, 2001, ERLINDA

FRANCISCO, doing business in the name and style of Cebu
Fountainhead Bakeshop and JULIANA PAMAONG,
petitioners, vs. RICARDO FERRER, JR., ANNETTE
FERRER, ERNESTO LO AND REBECCA LO, the Supreme
Court has ruled:
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"Moral damages are in the category of an award

designed to compensate the claimant for actual
injury suffered and not to impose a penalty on the
wrongdoer."17

"The person claiming moral damages must prove the

existence of bad faith by clear and convincing
evidence for the law always presumes good faith. It
is not enough that one merely suffered sleepless
nights, mental anguish, serious anxiety as the result
of the actuations of the other party. Invariably such
action must be shown to have been willfully done in
bad faith or will ill motive." 18 "Mere allegations of
besmirched reputation, embarrassment and
sleepless nights are insufficient to warrant an award
for moral damages. It must be shown that the
proximate cause thereof was the unlawful act or
omission of the [private respondent] petitioners."19

"An award of moral damages would require certain

conditions to be met, to wit: (1) first, there must be
an injury, whether physical, mental or psychological,
clearly sustained by the claimant; (2) second, there
must be culpable act or omission factually
established; (3) third, the wrongful act or omission
of the defendant is the proximate cause of the injury
sustained by the claimant; and (4) fourth, the award
of damages is predicated on any of the cases stated
in Article 2219" of the Civil Code.21

"It must again be stressed that moral damages are

emphatically not intended to enrich a plaintiff at the
expense of the defendant."22 "When awarded, moral
damages must not be palpably and scandalously
excessive as to indicate that it was the result of
passion, prejudice or corruption on the part of the
trial court judge"23 or appellate court justices.24

In the same fashion, to warrant the award of

exemplary damages, "[t]he wrongful act must be
accompanied by bad faith, and an award of
damages would be allowed only if the guilty party
acted in a wanton, fraudulent, reckless or malevolent
manner."25
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"The requirements of an award of exemplary

damages are: (1) they may be imposed by way of
example in addition to compensatory damages, and
only after the claimant's right to them has been
established; (2) that they cannot be recovered as a
matter of right, their determination depending upon
the amount of compensatory damages that may be
awarded to the claimant; (3) the act must be
accompanied by bad faith or done in a wanton,
fraudulent, oppressive or malevolent manner.

Applying the above jurisprudence in the case at bar, it bears

stressing that moral and exemplary damages cannot apply
because the wrongful act as imputed against the herein
respondent has not been established by the complainants in
their complaints. It is worth emphasizing that for the wrongful
act done on the part of the respondent to be established, it
must have been carefully alleged and substantiated well by the
complainants. It must be at the burden of the complainants to
establish the allegation that there was indeed a wrongful act
done on the part of the respondent that caused injury to them.
However, as far as the complainants’ position paper submitted
is concerned, there is no wrongful act done on the part of the
respondent been alleged and established. Absent of the
foregoing, complainants, who has the burden of proof on the
issue, has failed to discharge the same and have fallen short
to prove their claim.

7. Complainants alleged that they have substantiated their

allegation with Payslips indicating there with as ANNEX “A”,
however, as far as the received copy of their position paper by
the herein respondent, there was no pay slips attached.

8. In the complainants’ position paper, respondent was

astonished upon seeing the allegation of illegal dismissal
alleging therewith that Pablo was dismissed on April 22,
2022, Jamandre was dismissed on August 30, 2019,
Tambago was dismissed on February 21, 2022, Emerez was
dismissed in September 2022, and Lintangan was
dismissed in March 2022. They alleged that the names of the
enumerated complainants were dismissed without just and
valid cause. However, illegal dismissal case was not included
in the Complainants’ filed and executed Complaint.

9. Based on the attached pro forma complaint when the herein

complainants filed the instant case, nowhere in the said
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complaint that a cause of action for illegal dismissal was

alleged, declared, and filed constituting part of the instant
case. Thus, herein respondent argues that the allegation of
illegal dismissal was just inserted by herein complainants in
their submitted position paper and that the same was not even
included in their filed executed proforma complaint.

10. It is herein argued that the complaint for illegal dismissal

shall not be allowed to constitute the causes of actions that
suddenly appeared only in the submitted position paper
considering that said complaint or cause of action was not
part of the cases having been filed in the executed proforma
complaint which copy have been attached and annexed
herewith. Such inclusion or insertion shall be deemed illegal
and is not consistent with the rule on fair play.

11. It is to be noted that the complaint for illegal dismissal

was not included as among the causes of actions being
discussed by parties during the mediation and conciliation
proceeding because it was not among the causes of actions
that they complainants have concerns against herein
respondents as far as the filed pro forma complaints filed by
respondent.

12. That in view of paragraph (9), (10), & (11), herein

respondent argues that the inserted cause of action on illegal
dismissal is a stranger cause of action in the herein case at
bar which must not be given due course to be included in the
process.

13. Granting, arguendo, and only for the sake of argument

that illegal dismissal is among the causes of action filed by
complainants, still the allegation of illegal dismissal cannot be
tenable for being baseless, and that herein respondent denies
said allegation. And that based on the ancient rule on the
burden of proof, the burden rests upon the party who alleges
not upon the one who denies it which if translated into latin as
“ei incumbit probatio qui dicit, non qui negat”.

14. Further, complainants did not do anything to

substantiate their claim that their fellow complainants whose
names were mentioned have been dismissed. The sound of
their allegations are mere pure litanies unsubstantiated with
any proof or evidence. In short, their allegations are purely
bare allegations which according to jurisprudence as in the
case of G.R. No. 227523, August 29, 2018, AMALIA S.
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MENEZ (IN BEHALF OF THE LATE JONATHAN E. MENEZ)

VS. STATUS MARITIME CORPORATION, NAFTOTRADE
SHIPPING AND COMMERCIAL S.A., AND MOILEN
ALOYSIUS VILLEGAS, the high court has ruled, to wit:

“In view of the basic rule that mere allegation is not

evidence and is not equivalent to proof, the allegation is
essentially self-serving and devoid of any evidentiary
weight”.

15. Further, in the case of [ G.R. No. 221411, September

28, 2020] ITALKARAT 18, INC. PETITIONER, VS.
JURALDINE N. GERASMIO

“It is a well-settled rule, however, that before the

employer must bear the burden of proving that the
dismissal was legal, the employee must first establish by
substantial evidence the fact of his dismissal from
service. Bare allegations of constructive dismissal, when
uncorroborated by the evidence on record, cannot be
given credence”.

16. Hence, it is therefore counter-argued that the allegations

of dismissal by the complainants against the respondent bears
no weight and credence. It is incumbent upon the
complainants to establish the proof of their allegations by
substantial and convincing evidence that they were indeed
dismissed by the respondent. However, for the complainants
to be consistent in their allegation of dismissal or that they
were dismissed, it is required that they must first make it clear
to identify as to who really is their employer. Is it B-Mirk or is
it Coca-Cola?. Complainants’ failure to prove first their being
employees to either B-Mirk or Coca-Cola does simply say that
complainants are not precisely sure of their allegations of
dismissal.

17. Complainants’ claim of illegal dismissal could not be

attributed against B-Mirk because insofar as their claim for
employment is not with the latter, they argue continually that
they are Coca-Cola’s employees. Thus, complainants’ illegal
dismissal complainant is absent of logical basis. For the
complainants’ allegation to be logically coherent, they must
first be established by factual and convincing evidence who
really were their employer because as they were the party who
alleges dismissal, they must be the one to prove first who were
their employer, to sustain their allegation of dismissal and to
pinpoint who was the one that dismissed them. Absent of this,
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their allegation of dismissal is vague, and baseless. The

Supreme Court has used the decision that it held in the case
of Machica v. Roosevelt Services Center, Inc., quoting a
portion of the decision in the said case, to wit:

“The rule is that one who alleges a fact has the

burden of proving it; thus, petitioners were burdened
to prove their allegation that respondents dismissed
them from their employment. It must be stressed that
the evidence to prove this fact must be clear, positive
and convincing. The rule that the employer bears the
burden of proof in illegal dismissal cases finds no
application here because the respondents deny
having dismissed the petitioners.” (Emphasis and
underscoring supplied)

And in the case of G.R. No. 221411, September 28, 2020,

ITALKARAT 18, INC. VS. JURALDINE N. GERASMIO,
quoting a portion of the decision of the Honorable Supreme
Court, thus, reads:

“We have also clarified that there can be no question as to

the legality or illegality of a dismissal if the employee has
not discharged his burden to prove the fact of dismissal by
substantial evidence, to wit:

“It is true that in constructive dismissal cases, the

employer is charged with the burden of proving that
its conduct and action or the transfer of an employee
are for valid and legitimate grounds such as genuine
business necessity. However, it is likewise true that
in constructive dismissal cases, the employee has
the burden to prove first the fact of dismissal by
substantial evidence. Only then when the dismissal
is established that the burden shifts to the employer
to prove that the dismissal was for just and/or
authorized cause. The logic is simple — if there is no
dismissal, there can be no question as to its legality
or illegality. (Emphasis and underscoring supplied)”.

18. Complainants also alleged in their position paper that

they were deployed with Coca-Cola.

 This allegation by the complainants runs contrary

with the hiring documents such as contracts signed
by complainants with Bmirk before they were
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deployed by the herein respondent Bmirk to Coca-

Cola, and which simply proves the fact of their
employment with the respondent B-mirk.

 Moreover, Payslips and Proof of SSS, PAGIBIG AND

PHILHEALTH Remittances all have been borne by
B-mirk, and they do simply prove that
complainants are employees of B-Mirk, and it is B-
mirk that deployed them to its principal Coca-Cola.
That’s it.

19. Complainants’ allegation that they were supplied by a

manpower agency in Coca-Cola is simply a matter of
speculation. This allegation does not pose such a significant
question because it is true that B-Mirk being the service
provider of the principal Coca-Cola is the one supplying the
latter with people, tools and equipment, as the former is
engaged in the legitimate contracting services with the latter,
but to be precise, B-Mirk’s services with Coca-Cola is not
merely confined to supplying people, but to work out
contracted services with Coca-Cola as having governed with
service contracts which were already attached in the
submitted position paper.

20. Complainants’ allegation that they were being paid on a

daily basis does not pose a significant question because the
truth of the matter is that complainants have been engaged
under the employment of NO WORK NO PAY arrangement,
and the same are shown in the employment contract executed
by complainants and B-mirk which are already attached in the
submitted position paper.

21. And as to the issue of complainants’ complaint that they

were allegedly bodily searched by Security Guards upon
entering the premises of Coca-Cola is a senseless litany that
contains no significant issue to ponder upon. This explanation
is premised on the contention that it is a normal, ordinary
policy of the company to implement security searches within
the bound of their area for safety and precaution of the
Company’s assets, employees, suppliers, among others. And
since the complainants being workers deployed at the
premises of the Coca-Cola, they are bound to conform with the
Coca-Cola security policies such as policy on inspection.

22. They are working inside the Coca-Cola premises, the

permitted or permissible or legitimate job contracting or
subcontracting is the one allowed and permitted by law. It is
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an arrangement whereby a principal agrees to put out or farm

out with the contractor or subcontractor the performance or
completion of a specific job, work, or service within a definite
or predetermined period, regardless of whether such job,
work, or service is to be performed or completed within or
outside the premises of the principal. The foregoing simply
shows that the assignment of the complainants within the
premises of Coca-Cola, by itself, does not negate B-Mirk's
control over the means, method, and result of the
complainants' work. Job contracting is permissible "whether
such job, work, or service is to be performed or completed
within or outside the premises of the principal" for as long as
the elements of a labor-only contractor are not present.
Considering that B-Mirk is the provider of services, its
employees would necessarily work within the premises of its
client Coca-Cola in order for the former to perform its
contractual undertaking. The mere physical presence of the
complainants in Coca-Cola’s plant does not necessarily mean
that the latter controlled the means and method of the
complainants' work. The complainants, despite working in
Coca-Cola’s plant for most of the time, entered their day-to-
day attendance with B-Mirk by the direct supervision of their
Team Leaders and Supervisors, and that it is with them that
complainants/employees coordinate, or submit their leave
application or to request for a reliever whenever they could not
attend to work on the day or days due to some reasons. The
supervisors mentioned who were designated as on-site
supervisors from B-Mirk were the ones who oversaw the
performance of the work of the complainants. However, B-
Mirk supervision is not only limited to the supervision done
regularly by on-site Supervisors, because overall
administrative control and supervisions were constantly done
by the Main Human Resource Division in close coordination
with the Operations Division especially when involved
implementing disciplinary action to erring employees that
would consequently affect the manning and services
requirements to clients.

23. The complainants 201 File and their executed

Contract of Employment, and their issued B-Mirk
Employee Identification all speak impliedly of their
admission that they were hired and become employees of B-
Mirk. Then B-Mirk took the rigorous efforts to scout them
individually from nowhere, selected and trained them and
finding them documented and ready, they were then deployed
to their respective assignments wherein they were paid with
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the rightful wages based on the mandate of the law. Aside

from that they exactly paid of their wages, including their
contributions to the Social Security System (SSS), Philippine
Health Insurance Corporation (PhilHealth), and Home
Development Mutual Fund (HDMF, also known as Pag-IBIG).

24. This humble respondent most humbly rebuts and

opposes the claim of herein complainants which they
presented “that no point in their work that they were
directed by any employee of B-Mirk”. This language of the
complainants is commonly happening as a matter of
disguising that they were not guided in their work on what to
do from day-to-day against the fact that they were constantly
verbally reminded by their supervisors and team leaders
before going to delivery work and have been constantly
reminded also to submit report after the delivery work at the
end of the day. (see attached Operations Organizational Chart,
referred to as ANNEX 1 SERIES)

25. The above complaints as laid down by the herein

complainants are a kind of a rhetorical litanies. Firstly, their
claim that their job positions or functions are directly related
to the distribution and sale of Coca-Cola products and are
defined as covered by the CBA, so on and so forth, is a
senseless argument to sustain the same as basis of
employment. This is because in the normal course of life or
business operations, all positions or works in the company are
directly related to the operations of the business. It is the
skeptics like that of the complainants alone that authored the
hyper-acting to put significant emphasis on selected positions
disregarding the others, but the truth of the matter is that
every position works complementarily for the company’s
business and operations. B-Mirk employees, including the
complainants, whether as Warehouse personnel or Delivery
Service Assistant (DSA), perform functions that are non-core
to the manufacturing operations of Coca-Cola. Worth
mentioning, in fact, only company drivers deliver company
products. “DSA” functions are now even handled by
distributors.

For the company is analogous to the human body that is

made up of many parts, and that each part of which
independently functions in its own but complementing for the
healthy functioning of the entire human body system.
Applying this analogy to the business: when one employee or
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more are not working well, their performance could affect the
functioning of the other employee or the functioning of whole
department where they belong and would somehow affect the
whole business operations. This is because each employee or
department is complimentary to each other and affects the
entire business as a whole. For example, the work of the
janitor may seem to be insignificantly related to the production
of soft drinks at Coca-Cola, however, the day to day works of
the janitor cannot be divorced from the operations of the
productions or even in the warehouse works or even in the
office works because the janitorial works that are made
manifest by cleaning the external and internal premises, of the
company facilities and arranging things as well are
complementing to make the complex works of the company be
done smooth, and easier.

26. As far as the record of services rendered by complainants

Susano Rojales in his employment with B-Mirk is concerned,
some complainants had already served 5 years or more.
Hence, some of them are already eligible to avail of retirement
pay or relevant benefits if there may be if he applies for the
same. However, considering the language of the position paper
submitted by complainants, they did not express or file their
application for retirement with B-Mirk but with Coca-Cola
alone, and that it can simply be understood they did not
intend to avail retirement pay from B-Mirk because they did
not show any act to apply for the same with B-Mirk. It is
further contended that for retirement pay to be availed, it
must be expressly filed by the retiring employee with his
employer, and that the non-filing of the same does mean that
an employee retiring is not interested to avail of the same.

27. That the herein complainant has resigned from B-Mirk

on AUGUST 2, 2022, which means his length of services
with B-Mirk was only less than 5 years. Such could not
warrant to suffice his claim that he could avail of the
retirement pay because he had not even attained the
minimum 5 years services requirement which the law set forth
to qualify.

28. It is humbly argued that the wording of RA 7641 has

clearly set forth a minimum requirement of FIVE YEARS for an
employee to be able to avail of retirement pay. To further
sustain it, there is one rule of statutory construction does
sayeth in latin term “Expressio unius est exclusio alterius"
which does mean that “the expression of one thing is the
exclusion of the other". This is a common law principle for
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construing legislation which holds that a syntactical

presumption may be made that an express reference to one
matter excludes other matters. The said law allows only
“employee or employees”, and to be specific, the employee
referred therewith is one or those that have already rendered
at least 5 years of service with their employer who can avail of
retirement pay.

29. Applying said rule in the instant case, considering that

complainant Rojales and other complainants are not
employees of Coca-Cola, they could not avail of retirement pay
with the latter. On other hand, complainant Rojales and
others could avail of retirement pay with B-Mirk considering
their employment and length of services with the company
amounted for more than 5 years and those could sustain their
eligibility to avail retirement with B-Mirk; however, they must
apply or file to avail of the same.

30. Complainant and respondent B-Mirk’s engagement as

employee and employer is not covered and or governed by
Collective Bargaining Agreement because there was no CBA
that was established in the company ever since until present,
hence, complainant’s claim for CBA Benefits, and Wage
Increase based on CBA cannot be tenable in the absence of the
same.

31. In the absence of a Collective Bargaining Agreement at

B-Mirk as alleged by the herein humble respondent under
paragraph (13), complainant therefore cannot validly invoke
nor claim about CBA Wage, or CBA Wage Increase or Benefits,
because the absence of such clearly and simply makes the
claim of the complainant irrefutably founded on baseless
ground.

32. It is further contended that COMPLAINANT has no basis

for claiming CBA Benefits. As gleaned from the records, it is
worth stressing that the complainant should first care to prove
or substantiate that he is one of the members of the union at
B-Mirk. His mere claim that he is a “union member” is
significantly stranger because B-Mirk does not have and did
not have a union ever since until date.

33. Considering that complainants had not adduced any

proof to establish their membership with the union as above
explained and argued, it follows that complainants also have
no accredited personality to claim for the benefits be accorded
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to members thereof, and since the complainants had already

been paid based on DOLE Mandated Wage and all mandated
benefits have been complied with by B-Mirk, there is no
reason that they will be paid again more than what the law
has prescribed except when the same are stipulated in the
contract of employment, however, there is none so far.

34. It is reiterated that there is no basis that respondents be

paid of moral and exemplary damages. Where there is no
injury made by the respondents upon them, and that there is
no act of breach committed to them, hence there is no reason
that they will be compensated for their claim for moral and
exemplary damages considering it to be baseless, and
unfounded.

35. This complaint filed by complainants for their

regularization with the principal Coca-cola does not hold water
because B-mirk is a legitimate job contractor which has
complied with the substantial capitalization requirement as
required under D.O. 174-17 & based on jurisprudence.

36. The complainants has committed a fallacy of non

sequitur which is a formal logical fallacy characterized by
making arguments that did not follow with the logical
structure creating a logical gap between the premise or the
evidence provided, and the conclusion drawn. Even if the
premises are true, once it is not logically coherent with the
conclusion of the case, the same would be deemed fallacious
as in the instant complaint filed by the herein complainants.
Generally, formal fallacies are in fact non sequiturs because
they involve conclusions that do not naturally or logically
follow from the premises of the argument. It must be
mandatory and within the burden of the complainants to
ensure that their complaints are logically in order, however,
complainants in the instant case failed to comply with this
requirement.

37. Applying the fallacy of non sequitur in the instant case,

this humble respondent argues that the herein complainants’
complaints does not follow logical premises. This can be
simply examined based on the factual premises and to come
up with logical inference of the case, as follows:

A. The complainants are employees of B-Mirk. (Yes, Factually

Correct)
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B. The complainants, as employees who have been for years,

are already regular employees of B-Mirk. (Yes, Factually &
Logically Correct)
C. The complainants, being regular employees of B-Mirk
have been working and assigned by the latter at its client
Coca-Cola. (Yes, Factually Correct)
D. Therefore, considering that the complainants are regular
employees of B-Mirk, and that they been assigned by the
latter for years that made to work at its client Coca-Cola,
said complainants now become regular employees of
Coca-Cola. (Illogical Conclusion)

38. The conclusion of the case is an example of Illogical

Inference because the argument as raised in the case has
committed the fallacy of non sequitur because the conclusion
of the arguments of the complainants does not follow
according to the order of the premises. This is to say that a
fallacious argument is no argument at all.

WHEREFORE, considering the foregoing, this humble respondent

most respectfully claimed that:

1. B-Mirk is a legitimate job contractor based on criteria set

forth by law.

2. Complainants are employees of the B-Mirk, hence,

should not be regularized under respondent Coca-Cola
and are no longer entitled to the benefits pertaining to
regular employees of respondent Coca-Cola.

3. Complainants have already been paid by B-Mirk with

DOLE Mandated Salary/wage; hence, they are no longer
qualified to be paid again for the foregoing.

4. Complainants are not reasonable and lawful to be paid of

attorney’s fee, moral and exemplary damages nor of
benefits under the CBA.

5. Complainants claim for illegal dismissal are unfounded

and baseless.

PRAYER
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Respondent B-Mirk, respectfully prays that this case be

DISMISSED for utter lack of merit.

Other reliefs just and equitable are likewise prayed for.

Antipolo City for Quezon City.

July 7, 2023, 2023.

RAMON A. CASTRO
Representative of Respondents
No. 9 Pizarro St. Vista Verde Executive Village
Antipolo City

Copy furnished:

SUSANO ROJALES, ET. AL.,

Complainants

COCA-COLA BEVERAGES PHILS, INC.

Co-Respondent