Republic of the Philippines

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION
Quezon City
National Capital Region
MARITES P. AMABAO AND
FRANCISCO A. AMABAO,
Complaina
nts,
-versus-

NLRC CASE NO. NCR-05-06289-

15
Hon. L.A. Gaudencio P.
Demaisip, Jr.
EVERGOOD
FOOD
PRODUCT/ALEX S. LAO,
Respondents.
x----------------------------------------------x

JOINT REPLY
[to Respondents Undated Position Paper]
Complainants, by counsel, to this Honorable Office, by
way of a Reply to respondents undated Position Paper, most
respectfully set forth the following:
At the outset, complainants would like to emphasize
that respondents Position Paper is bereft, in fact and in law,
of any substantive justifications that would negate
complainants clear and undoubted grounds to support their
conviction that they were illegally dismissed.
Rather than dwelling in respondents bare say so and
unfounded suppositions, complainants, with all humility,
further advance the following arguments, in view of
bolstering their established points in this instant case:

THE
COMPLAINANTS
DID
NOT
VOLUNTARILY SEPARATE THEMSELVES
FROM
THEIR
JOBS.
THEY
WERE
ILLEGALLY DISMISSED
It is already settled that in a dismissal situation, the
burden of proof lies with the employer to show that the
dismissal was for a just cause. In the present case,
respondents claim that there was no dismissal to speak of.
They want to make it appear that complainants voluntarily
separated themselves from the respondent company. Simply
put, to respondents, complainants abandoned their jobs and
were not even dismissed.
It befits the complainants to highlight early on the
blatant lies asserted by the respondents in their undated
Position Paper.
It must be stressed that complainants had already filed
their complaints before the Department of Labor and
Employment on 19 March 2015, even before their
suspension were made effective from 25 March 2015 to 08
April 2015. The complaint before the SEnA Office was
actually triggered by the unjustified refusal of the
respondents to pay complainants their salaries for the month
of February 2015. This callous act of the respondents is
undoubtedly a form of constructive dismissal. The illegal
dismissal of the complainants was made actual when they
were denied entry to the companys premises on 09 April
2015.
The jurisprudential rule is that abandonment is a matter
of intention that cannot be lightly presumed from equivocal
acts. To constitute abandonment, two elements must concur:
(1) the failure to report for work or absence without valid or
justifiable reason, and (2) a clear intent, manifested through
overt acts, to sever the employer-employee relationship. The
employer bears the burden of showing a deliberate and
unjustified refusal by the employee to resume his
employment without any intention of returning. (Pentagon
Steel Corporation v. Court of Appeals, G.R. No.
174141, June 26, 2009).

In the instant case, the respondents did not cite any

evidence to show that the complainants undoubtedly and
utterly intended to abandon their jobs or to sever the
employer-employee relationship. The complainants filing of
the complaint for illegal dismissal on 19 March 2015 strongly
evinces against respondents accusation of abandonment; it
is illogical for complainants to abandon their employment
and, thereafter, file a complaint for illegal dismissal. That
abandonment is negated finds support in a long line of cases
where the immediate filing of a complaint for illegal dismissal
was coupled with a prayer for reinstatement; the filing of the
complaint for illegal dismissal is proof enough of the desire to
return to work. The prayer for reinstatement, as in this case,
speaks against any intent to sever the employer-employee
relationship.
As held by the Supreme Court in Samarca v. Arc-Men
Industries, Inc. 459 Phil. 506, 516 (2003):
Abandonment is a matter of
intention
and
cannot
lightly
be
presumed from certain equivocal acts.
To constitute abandonment, there must
be clear proof of deliberate and
unjustified intent to sever the employee
relationship. Clearly, the operative act is
still the employees ultimate act of
putting an end to his employment.
If indeed the respondents are certain to have a solid
ground on which their theory that complainants were never
dismissed is founded, then why not put forward their
evidence and forthright discharge their burden of proof?
Respondents confront complainants to prove their
allegations of illegal suspension and illegal dismissal even as
they label their actuations as a management prerogative of
instilling discipline in their employees. Respondents even
claim that complainants were given memos and disciplinary
action/s for the violation of respondents company rules and
regulation that causes damages and delays in the
production.
But, where are the memos they are adverting to in their
23 March 2015 Memoranda and in their undated position
3

paper? What they appended to their undated position paper

are sheer letters of suspension issued to the complainants.
Did they afford the complainants the right to face and
answer the charges against them prior to the issuance of the
suspension letters against them? Clear as crystal, the
answer to this query is in the negative. There is no showing
that due process was observed even as no formal letter of
charges were issued to the complainants before they were
put under fifteen (15) days suspension from work.
Equally appalling is the bare allegations of the
respondents that complainants employment performances
and attitude towards their work were not altogether
satisfactory as they had allegedly committed several
infractions of company rules and regulations such as
tardiness, unexcused absences and negligence from work.
Again, the temerity of the respondents to lie must be put to
stop.
Attached hereto, and made an integral parts hereof, as
ANNEX A to ANNEX A-166 are the attendance record
of the complainants for the period covering 23 October 2014
to 25 February 2015 showing that complainants are working
almost 14 hours each day without enough rests. If working
more than 14 hours each day in the interests of their
employer is not an indicum of hard work and dedication,
then what must the complainants do to exude the same?
For quick reference, listed hereunder is the summary of
complainants attendance record from 23 October 2014 to
25 February 2015, to wit:
ATTENDANCE FOR THE PERIOD COVERING 23
DATE
DAY
FRANKIE AMABAO
TIME IN
TIME OUT
23 OCT 14
THUR 7:43 A.M.
11:09 P.M.
24 OCT 14
FRI
7:08 A.M.
11:40 P.M.
25 OCT 14
SAT
6:43 A.M.
11:03 P.M.
26 OCT 14
SUN
7:25 A.M.
10:34 P.M.
27 OCT 14
MON
6:58 A.M. 11: 34 P.M.
28 OCT 14
TUE
7:00 A.M.
11:32 P.M.
29 OCT 14
WED
6:55 A.M.
11:32 P.M.
30 OCT 14
THUR 7:00 A.M. 12:01 A.M.
02 NOV 14
SUN
6:53 A.M.
11:49 P.M.
03 NOV 14
MON
6:53 A.M.
11:40 P.M.
04 NOV 14
TUE
7:48 A.M.
11:31 P.M.
05 NOV 14
WED
7:05 A.M.
11:38 P.M.
06 NOV 14
THUR 6:48 A.M.
11:33 P.M.
07 NOV 14
FRI
6:55 A.M.
10:41 P.M.
08 NOV 14
SAT
6:35 A.M.
12:00 P.M.
09 NOV 14
SUN
7:00 A.M.
12:04 P.M.

October 2014 to 25 February 2015

MARITESS AMABAO
TIME IN
TIME OUT
9:57 A.M.
3:32 A.M. (24 OCT 14)
10:03 A.M. 4:15 A.M. (25 OCT 14)
9:50 A.M.
5:05 A.M. (26 OCT 14)
9:58 A.M.
10:02 A.M.
10:32 A.M.
10:55 A.M.
10:02 A.M.
9:55 A.M.
10:01 A.M.
11:53 A.M.
10:02 A.M.
10:00 A.M.

4:31 A.M. (28 OCT 14)

5:33 A.M. (29 OCT 14)
6:30 A.M. (30 OCT 14)
8:35 A.M. (31 OCT 14)
4:13 A.M. (03 NOV 14)
6:46 A.M. (04 NOV 14)
6:01 A.M. (05 NOV 14)
3:53 A.M. (06 NOV 14)
5:03 A.M. (07 NOV 14)
5:00 A.M. (08 NOV 14)

10:04 A.M.

5:38 A.M. (10 NOV 14)

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

NOV
NOV
NOV
NOV
NOV
NOV
NOV
NOV
NOV
NOV
NOV
NOV
NOV
NOV
NOV
NOV

14
14
14
14
14
14
14
14
14
14
14
14
14
14
14
14

MON
TUE
WED
THUR
FRI
SAT
SUN
MON
TUE
WED
THUR
FRI
SAT
SUN
MON
TUES

6:58
6:49
7:27
7:34
6:58
7:16
7:11
7:00
7:30
7:15
7:08
7:00
6:40
7:40
7:14

A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.

12:04 P.M.
11:03 P.M.
11:35 P.M.
11:05 P.M.
11:16 P.M.
12:12 P.M.
11:30 P.M.
12:00 A.M.
11.39 P.M.
11:04 P.M.
10:59 P.M.
12:05 A.M.
11:54 P.M.
11:16 P.M.
12:02 A.M.

10:55 A.M.
10:22 A.M.
9:59 A.M.
10:05 A.M.
10:06 A.M.

4:06
2:13
3:31
4:56
4:07

A.M.
A.M.
A.M.
A.M.
A.M.

(11
(12
(13
(14
(15

NOV
NOV
NOV
NOV
NOV

14)
14)
14)
14)
14)

9:58 A.M.
9:59 A.M.
10:24 A.M.
10:03 A.M.
10:02 A.M.
10:03 A.M.

5:42
6:22
4:03
3:35
4:44
5:32

A.M.
A.M.
A.M.
A.M.
A.M.
A.M.

(17
(18
(19
(20
(21
(22

NOV
NOV
NOV
NOV
NOV
NOV

14)
14)
14)
14)
14)
14)

9:56 A.M.
10:04 A.M.
10:03 A.M.

26 NOV 14
27 NOV 14
28 NOV 14
29 NOV 14
30 NOV 14
01 DEC 14
02 DEC 14
03 DEC 14

WED
THUR
FRI
SAT
SUN
MON
TUE
WED

7:21
7:12
7:22
6:34
6:53
7:36
7:32
7:34

A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.

12:30 A.M.
11:34 P.M.
12:03 A.M.
11:44 P.M.
11:00 P.M.
11:40 P.M.
11:34 P.M.
11:32 P.M.

10:08 A.M.
10:00 A.M.
9:59 A.M.

4:52 A.M. (24 NOV 14)

5:00 A.M. (25 NOV 14)
12:05 A.M. (26 NOV
14)
2:43 A.M. (27 NOV 14)
4:32 A.M. (28 NOV 14)
4:31 A.M. (29 NOV 14)

04
05
06
07
08
09
10
11
12
13
14
15
16
17
18

THUR
FRI
SAT
SUN
MON
TUE
WED
THUR
FRI
SAT
SUN
MON
TUE
WED
THUR

7:30
7:26
6:53
7:04
7:04
7:28
7:37
7:52
7:03
6:52
8:05
7:31
7:45
7:37
8:53

A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.

11:18 P.M.
12:03 A.M.
11:57 P.M.
12:00 A.M.
12:10 A.M.
11:02 P.M.
10:09 P.M.
12:00 A.M.
11:38 P.M.
12:30 P.M.
11:02 P.M.
12:00 A.M.
12:03 A.M.
1:21 A.M.
7:02 P.M.

10:26 A.M.
10:02 A.M.

2:32 A.M. (01 DEC 14)

2:33 A.M. (02 DEC 14)
11:44 P.M.
12:03 A.M. (04 DEC
14)
3:32 A.M. (05 DEC 14)
4:02 A.M. (06 DEC 14)

9:50 A.M.
10:07 A.M.
10:04 A.M.
10:06 A.M.
1:03 P.M.
10:43 A.M.

6:00
5:13
4:02
2:06
6:09
7:00

10:29
10:29
10:02
10:15
10:59

5:30 A.M. (15 DEC 14)

6:33 A.M. (16 DEC 14)
5:37 A.M. (17 DEC 14)
5:00 A.M. (18 DEC 14)
12:00 A.M. (19 DEC
14)
12:19 A.M. (20 DEC
14)
9:44 P.M.
10:32 P.M.
10:51 P.M.
7:26 P.M.
10:02 A.M. (27 DEC
14)
7:00 A.M. (28 DEC 14)

DEC
DEC
DEC
DEC
DEC
DEC
DEC
DEC
DEC
DEC
DEC
DEC
DEC
DEC
DEC

14
14
14
14
14
14
14
14
14
14
14
14
14
14
14

19 DEC 14

10:02
10:02
10:13
10:02

A.M.
A.M.
A.M.
A.M.

A.M.
A.M.
A.M.
A.M.
A.M.

FRI

6:52 A.M.

7:04 P.M.

7:14 A.M.

14
14
14
14
14

SAT
SUN
MON
TUE
FRI

6:52 A.M.
6:59 A.M.
6:56 A.M.

7:11 P.M.
7:06 P.M.
7:04 P.M.

6:39 P.M.

7:15 A.M.

7:32 A.M.
7:30 A.M.
7:43 A.M.
7:24 A.M.
5:28 P.M.

27 DEC 14

SAT

6:48 P.M.

28 DEC 14

SUN

6:55 P.M.

29 DEC 14

MON

6:55 P.M.

30 DEC 14

TUE

7:02 P.M.

02 JAN 15
03 JAN 15

FRI
SAT

8:27 A.M.
6:56 A.M.

7:07 A.M.
(28 DEC
14)
7:15 A.M.
(29 DEC
14)
7:27 A.M.
(30 DEC
14)
12:02 A.M.
(31 DEC
14)
11:03 P.M.
12:23 P.M.

20
21
22
23
26

DEC
DEC
DEC
DEC
DEC

5:50 P.M.

A.M.
A.M.
A.M.
A.M.
A.M.
A.M.

(08
(09
(10
(11
(12
(13

DEC
DEC
DEC
DEC
DEC
DEC

14)
14)
14)
14)
14)
14)

5:56 P.M.

11:07 A.M. (29 DEC

14)

5:52 P.M.

7:00 A.M. (30 DEC 14)

5:57 P.M.

6:00 A.M. (31 DEC 14)

9:59 A.M.

9:37 A.M. (03 JAN 15)

04
05
06
07
08
09

JAN
JAN
JAN
JAN
JAN
JAN

15
15
15
15
15
15

SUN
MON
TUE
WED
THUR
FRI

7:01
7:01
6:56
7:30
7:24
7:28

10
11
12
13
14
15
16
17
18
19

JAN
JAN
JAN
JAN
JAN
JAN
JAN
JAN
JAN
JAN

15
15
15
15
15
15
15
15
15
15

SAT
SUN
MON
TUE
WED
THUR
FRI
SAT
SUN
MON

6:26 A.M.
6:45 A.M.

11:30 P.M.
11:34 P.M.
11:01 P.M.
11:35 P.M.
11:03 P.M.
12:00 A.M.
(10 JAN
15)
12:03 P.M.
10:02 P.M.

7:27
7:04
7:28
7:29
7:41
7:26
6:52

10:02
11:02
10:08
11:05
12:01
10:07
10:32

20 JAN 15
21 JAN 15

TUE
WED

7:01 A.M.
6:30 A.M.

10:45 P.M.
10:34 P.M.

9:57 A.M.
9:55 A.M.

22
23
24
25

15
15
15
15

THUR
FRI
SAT
SUN

7:24
6:30
6:30
6:51

26 JAN 15

MON

27 JAN 15
28 JAN 15
29 JAN 15
30 JAN 15
31 JAN 15
01 FEB 15
02 FEB 15
03 FEB 15
04 FEB 15
05 FEB 15
06 FEB 15

TUE
WED
THUR
FRI
SAT
SUN
MON
TUE
WED
THUR
FRI

7:37
7:54
7:29
6:30
6:45
7:53
7:21
7;20
7:31
7:00
6:47

A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.

10:34 P.M.
11:00 P.M.
12:00 P.M.
12:00 A.M.
(26 JAN
15)
12:04 A.M.
(27 JAN
15)
10:46 P.M.

07
08
09
10
11

15
15
15
15
15

SAT
SUN
MON
TUE
WED

7:21
7:00
7:08
7:04

A.M.
A.M.
A.M.
A.M.

10:02 P.M.
11:10 P.M.
12:34 P.M.
10:37 P.M.
10:31 P.M.
10:07 P.M.
11:04 P.M.
10:00 P.M.
12:02 A.M.
(07 FEB
15)
12:27 P.M.
10:13 P.M.
10:20 P.M.
10:06 P.M.

12 FEB 15
13 FEB 15
14 FEB 15
15 FEB 15
16 FEB 15
17 FEB 15
18 FEB 15
19 FEB15
20 FEB 15
21 FEB15
22 FEB 15
23 FEB 15
24 FEB 15

THUR
FRI
SAT
SUN
MON
TUE
WED
THUR
FRI
SAT
SUN
MON
TUE

7:17 A.M.
7:22 A.M.

11:08 P.M.
11:03 P.M.

7:40
6:59
7:40
6:25
7:22
7:24
7:16
7:11
7:12
7:17

9:34 P.M.
10:33 P.M.
10:40 P.M.

JAN
JAN
JAN
JAN

FEB
FEB
FEB
FEB
FEB

A.M.
A.M.
A.M.
A.M.
A.M.
A.M.

A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.

A.M.
A.M.
A.M.
A.M.

8:02 A.M.

A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.
A.M.

10:06
11:10
12:12
10:28
11:04
11:07

P.M.
P.M.
P.M.
P.M.
P.M.
P.M.
P.M.

P.M.
P.M.
P.M.
P.M.
P.M.
P.M.

9:56 A.M.
9:58 A.M.
10:49 A.M.
9:58 A.M.
9:58 A.M.
9:57 A.M.

6:02
6:46
4:37
3:25
5:41
7:48

A.M.
A.M.
A.M.
A.M.
A.M.
A.M.

(05
(06
(07
(08
(09
(10

JAN
JAN
JAN
JAN
JAN
JAN

15)
15)
15)
15)
15)
15)

10:04 A.M.
10:01 A.M.
9:55 A.M.
10:01 A.M.
10:00 A.M.

4:02
4:13
4:05
2:32
4:30

A.M.
A.M.
A.M.
A.M.
A.M.

(12
(13
(14
(15
(16

JAN
JAN
JAN
JAN
JAN

15)
15)
15)
15)
15)

10:00 A.M.
10:01 A.M.

9:59 A.M.
9:58 A.M.

3:18 A.M. (19 JAN 15 )

12:04 A.M. (20 JAN
15)
3:33 A.M. (21 JAN 15)
12:05 A.M. (22 JAN
15)
4:30 A.M. (23 JAN 15)
5:33 A.M. (24 JAN 15)

10:27 A.M.

5:08 A.M. (26 JAN 15)

10:18 A.M.

6:18 A.M. (27 JAN 15)

9:58 A.M.
12:00 P.M.
10:00 A.M.
10:02 A.M.
10:59 A.M.

7:00 A.M. (28 JAN 15)

3:25 A.M. (29 JAN 15)
5:38 A.M. (30 JAN 15)
6:39 A.M. (31 JAN 15)
4:00 A.M. (01 FEB 15)

10:38 A.M.
9:54 A.M.
10:03 A.M.
9:52 A.M.
10:03 A.M.

5:01 A.M. (03 FEB 15)

3:30 A.M. (04 FEB 15)
7:11 A.M. (05 FEB15)
4:03 A.M. (06 FEB15)
3:30 A.M. (07 FEB 15)

10:00 A.M.
9:57 A.M.
9:53 A.M.
9:57 A.M.
9:58 A.M.
10:00 A.M.

2:32 A.M. (09 FEB 15)

12:00 A.M. (10 FEB15)
12:00 A.M. (11 FEB15)
12:00 A.M. (12 FEB
15)
4:01 A.M. (13 FEB 15)
5:00 AM (14 FEB 15)

10:55 A.M.
9:52 A.M.
10:02 A.M.
9:52 A.M
9:59 A.M.
10:19 A.M.

3:10 A.M. (16 FEB 15)

4:52 A.M. (17 FEB15)
4:02 A.M. (18 FEB 15)
2:30 A.M. (19 FEB 15)
3:37 A.M. (20 FEB 15)
5:05 A.M. (21 FEB 15)

10:57 A.M.
9:59 A.M.
9:54 A.M.

3:30 A.M. (23 FEB 15)

3:33 A.M. (24 FEB15)
12:04 A.M. (25 FEB
15)

25 FEB 15

WED

7:46 A.M.

11:05 P.M.

10:00 A.M.

2:07 A.M. (26 FEB 15)

It is needless to overemphasize that the scales of

justice must tilt in favor of herein complainants. This
conclusion is consistent with the rule that the employers
cause can only succeed on the strength of its own evidence
and not on the weakness of the employees evidence.
(Functional, Inc. vs. Granfil, G.R. No. 176377,
November 16, 2011).
The rule is long and well settled that, in illegal dismissal
cases , the burden of proof is upon the employer to show
that the employees termination from service is for a just and
valid cause. The employers case succeeds or fails on the
strength of its evidence and not the weakness of that
adduced by the employee, in keeping with the principle that
the scales of justice should be tilted in favor of the latter in
case of doubt in the evidence presented by them. Often
described as more than a mere scintilla, the quantum of
proof is substantial evidence which is understood as such
relevant evidence as a reasonable mind might accept as
adequate to support a conclusion, even if other equally
reasonable
minds
might
conceivably
opine
otherwise. Failure of the employer to discharge the
foregoing onus would mean that the dismissal is not justified
and therefore illegal. (Functional, Inc. vs. Granfil, G.R.
No. 176377, November 16, 2011).
In the light of the foregoing discussion, it is now
crystal
clear that respondents advancement that
complainants were never dismissed is unmeritorious. Neither
does their say of abandonment is tenable in any
circumstances even as their burden of proof was not
discharged convincingly. Definitely, therefore, complainants
were illegally dismissed. Consequently, respondents must
reinstate complainants to their former positions without loss
of seniority rights and other privileges with the payment of
full backwages plus other monetary claims herein prayed for.
The arguments and/or discussion contained in
complainants Position Paper, dated 09 July 2015, are hereby
re-pleaded and made part hereof by reference.
As to the other issues in this case, the same were
already lengthily and sufficiently discussed in complainants
7

Position Paper, dated 09 July 2015, and are hereby repleaded by reference.
As to the other issues and/or points raised by
respondents in their undated Position Paper, the same are
either already addressed in complainants Position Paper or
are plainly irrelevant in this case.
WHEREFORE, in view of all the foregoing, it is most
respectfully prayed for that, after due consideration, a
DECISION BE RENDERED in favor of the Complainants as
follows:
1.
DECLARING Complainants to have been DENIED
DUE PROCESS and their DISMISSAL as ILLEGAL;
2.
DIRECTING
Respondents
to
immediately
REINSTATE the Complainants to their former positions
without loss of seniority rights and other privileges under the
law and the payment of their FULL BACKWAGES , inclusive
of allowances, and to other benefits or their monetary
equivalent computed from the time their compensations
were withheld from them up to the time of their actual
reinstatement;
3.
HOLDING Respondents SOLIDARILY LIABLE for
other monetary claims herein demanded as well as
DAMAGES in the amount of ONE HUNDRED THOUSAND
(P100,000.00)
PESOS. FOR EACH COMPLAINANT, as
moral damages and TWO HUNDRED THOUSAND
(P200,000.00) PESOS, FOR EACH COMPLAINANT, as
exemplary damages;
4. DECLARING Respondents SOLIDARILY LIABLE to
reimburse Complainants all THEIR litigation and other related
expenses, including attorneys fees equivalent to ten (10%)
percent of the total monetary award.
OTHER RELIEFS deemed just and equitable under the
premises are likewise prayed for.
Quezon City , 10 September 2015.

LAWIN
(Legal Advocates for Workers INterest)
Counsel for the Complainants
Room 206, Jiao Building
2 Timog Avenue, Quezon City
Email address: lawin2setufree@yahoo.com
Telefax (02) 373-18-44

ERNESTO R. ARELLANO
PTR No. 0560896; 01-05-15; Q.C.
IBP No. 0981335; 01-05-15; CALMANA
ROLL No. 22660
MCLE No. IV-0017780; 22 April 2013

JASPER C. BALBOA
PTR No. 0595301; 01-06-15; Q.C.
IBP No. 0982982; 01-06-15; MANILA I
ROLL No. 63288
MCLE Compliance until 14 April 2016
Admitted to the Bar on 07 May 2014

COPY FURNISHED: by hand and during hearing

ATTY. JOSELITO A. COMETA
Counsel for the Respondents
EVERGOOD FOOD PRODUCT/ ALEX S. LAO
175 Quirino Highway, Baesa, Quezon
City
Received by: ______________________
Time and date: ______________________