Republic of the Philippines

NATIONAL LABOR RELATIONS COMMISSION

Regional Arbitration Branch No. XI
Davao City

JESSIE V. MONQUIL, GREGORY N.

DELA PEŇA, ELMAR ZABATE NLRC RAB (OFW)
AND NOLI C. MORALES XI-05-00434-17
Complainants;
- versus - FOR: MONEY CLAIMS
AL ASSAL MANPOWER, INC. AND
EVANGELINE L. FABIAN –
CHAIRMAN OF THE BOARD
Respondents.
x-------------------------------------------------------------x

POSITION PAPER
COMPLAINANTS, assisted by the undersigned counsel and unto
this Honorable Labor Arbitration Office, most respectfully submit this
Position Paper and aver the following to wit:

PREFATORY STATEMENT
Quitclaims are ineffective in barring recovery for the full measure
of the worker's rights and that acceptance of benefits therefrom does
not amount to estoppel.
Acceptance of those benefits would not amount to estoppel. The
reason is plain. Employer and employee obviously do not stand on the
same footing. The employer drove the employee to the wall. The latter
must have to get hold of money. If out of a job, he has to face the harsh
necessities of life. He thus found himself in no position to resist money
proffered. His, then, is a case of adherence, not of choice.

PARTIES
The Complainants in this case are:
a) JESSIE T. MONQUIL, of legal age, Filipino and a resident of San
Isidro, Sta. Maria, Davao Occidental;
b) NOLI C. MORALES, of legal age, Filipino and a resident of Km 11
Purok 3 Bayview, Sasa, Davao City;
c) ELMAR T. ZABATE, of legal age, Filipino and a resident of Purok 1
Sitio Soriano, Catalunan Grande, Davao City;
1
 d) GREGORY N. DELA PEŇA, of legal age, Filipino and a resident of
Km 11 Bayview, Sasa, Davao City.

The Complainants could be served with summons and other legal

processes of this Honorable Office at Ateneo Legal Aid Services, 2/F
Dotterweich Hall, Jacinto Street, Davao City. The Complainants have
capacity to sue and be sued.
The Respondent is AL ASSAL MANPOWER, INC., a domestic
corporation with principal address at 2656 Taft Avenue, Malate, Manila.
The Respondent is duly represented by EVANGELINE L. FABIAN. The
Respondent may be served with notices and other processes of this
Honorable Court in the same aforementioned address.

STATEMENT OF FACTS
The Complainants were overseas Filipino workers engaged to
work as drivers in Kingdom of Saudi Arabia under Naqel Express. The
Complainants were employed through the local recruitment and
placement agency known as Al Assal Manpower, Inc.
The Complainants learned that Al Assal Manpower, Inc., a Davao-
based recruitment and placement agency was looking for drivers to be
deployed in the Kingdom of Saudi Arabia. Once the Complainants
completed the requirements, they were set to be deployed in the year
2015.
The Complainants signed a Contract of Employment (ANNEXES
“A-1”, “A-2”, “A-3” and “A-4”) on February 17, 2015 in Davao City. The
first contract signed in Davao City reflected the basic terms and
conditions for employment contracts for overseas Filipino workers.
Among others were the (1) site of employment, (2) contract duration,
(3) employee’s position, (4) basic monthly salary of SAR1 1,500.00, (5)
regular working hours, (6) overtime pay, (7) Food Allowance of SAR
300.00 which was added to the basic salary, (8) leave with pay, (9) free
transportation, (10) free housing, (11) free medical and dental services,
(12) grounds for termination of employment. However, the said
contract indicated that Complainants were single, but in truth and in
fact Complainants are married.
When the Complainants arrived in Manila and scheduled to be
deployed, they were made to sign another Contract of Employment
(ANNEXES “B-1”, “B-2”, “B-3” and “B-4”) on March 15, 2015 which
indicated a difference of the food allowance equivalent to only SAR
200.00. Moreover, the second contract of employment already reflected

1 Saudi Arabian Riyal

2
that Complainants were married. Notwithstanding the correction of
their status, the Complainants contested the terms of the contract as
well as the fact that said contract was a mere photocopy and the
certifications and/or stamps were already dated in 2013. nevertheless,
the Complainants signed the second contract because Al Assal
Manpower, Inc. refuses to process their tickets going to Kingdom of
Saundi Arabia if they refuse to sign the same. Considering that
Complainants already spent so much for processing their requirements
for employment, it would be disadvantageous not to pursue the same
Thus, Complainants left the Philippines only March15, 2015 and arrived
in the Kingdom of Saudi Arabia on March 16, 2015.
Upon arrival, the Complainants were subjected to a three (3)
month period of training wherein they were made to drive locally. Their
trips were within the regular working hours and within the area of
Riyadh only. After the three (3) month period, their trip schedules were
substantially changed. They were now assigned to inter-city trips which
exceeded the regular working hours which was a maximum of eight (8)
hours and even beyond the six-day per week regular working days. The
inter-city trips would require driving for at least nineteen (19) straight
hours and for at least one thousand five hundred (1500) kilometers,
depending on the destination of the trip. The trips were closely
monitored by the staff of Naqel Express by recording the time of
departure and providing for an estimated time of arrival as shown in
their Trip Plan Report (ANNEXES “C-1”, “C-2”, “C-3” and “C-4”) . The
Company likewise installed a tracking device on the vehicle which will
show whether the vehicle en route to the destination or at a stop.
Whenever it was at a stop, they will be contacted by the company’s
personnel.
The most alarming practice by the Naqel Express was that when
the employee-driver will not arrive at the estimated time of arrival as
appearing on their Trip Plan Report, the company will not compensate
them for that said trip on account of being late despite the long hours of
driving. Trip Allowance Reports (ANNEXES “D-1”, “D-2”, “D-3” and “D-
4”) are herein attached to show a summary of the total kilometers
travelled by the Complainants per Trip Plan Report which will show the
number of hours of exceeded the eight (8) – hour regular working hours
based on the allowable speed limit of 80 kilometers per hour of KSA.
Moreover, while Complainants were made to drive more than the
regular hours of work, they were not paid overtime. They are only paid
overtime pay if there will be pick up or delivery at their destination and
the overtime shall be strictly limited to three (3) hours only as
appearing Overtime Sheet (ANNEXES “E-1”, “E-2”, “E-3” and “E-4”) even
though in truth and in fact, the trip exceeded three (3) hours.

3
 As a result of this strict schedule by Naqel Express, the
Complainants often violated traffic rules of the KSA2 and corresponding
deductions on their basic salaries were made by the Naqel Express as
shown on the corresponding pay slips of the Complainants. The
Complainants, however, do have a complete record of their respective
pay slips.
It is worthy to note that these salary deductions were not
indicated in the Contract of Employment duly signed by the
Complainants. While they were given a copy of the traffic violations and
the corresponding deduction for the fines for such violations by Naqel
Express, some of the traffic violations do not correspond to the ticket
that were personally received by the Complainants. A comparative of
the Traffic Violations Report issued by Naqel Express and the actual
ticket received by the complainants are herein attached (ANNEX “F”).
Pursuant to the law and the practice in KSA, there are traffic
violations wherein the violators do not receive an actual ticket such as
those captured electronically through the cameras while some
violations such as not wearing seatbelts the actual traffic violation
tickets are issued by the traffic enforcers. Interestingly, traffic violations
such as absence of a mud guard on the vehicle, while the same is not
actually attributable to the Complainants, it was still the latter who
shoulder the burden of the fine for such violation. In addition, Naqel
Express’ deductions do not necessarily correspond to the Schedule of
Fees/ Penalties for Violations (ANNEX “G”) of the KSA. Some violations
are simply made up by the Company in order to claim deductions from
herein Complainants’ salaries.
The complainants often visited the Human Resource Department
of the employer; however, the visits and queries were futile as they
were told that they will receive an e-mail regarding their queries, which
e-mails were never received by the Complainants.
The Complainants endured through these working conditions
until the end of their two-year contract with NAQEL EXPRESS on March
16, 2017. Before the company will issue their exit visas and ticket bound
for the Philippines, they were required to execute a DECLARATION
(FINAL EXIT) (ANNEXES “H-1”, “H-2”,”H-3” and “H-4”) wherein they
have to declare that they have received all their entitlements and that
they voluntarily waived all their rights to file a complaint against the
herein Respondent and its principal in any court.
However, there was nothing voluntary about the said
DECLARATION (FINAL EXIT) as this was a condition before they will be
issued their plane tickets and exit visas. While the Complainants do not

2 Kingdom of Saudi Arabia

4
wish to waive at all any right to file a complaint against the respondent
and NAQEL EXPRESS, they were left with no other choice.
On April 9, 2017, the Complainants arrived in the Philippines and
lodged a complaint against herein Respondent before the National
Labor Relations Commission which conducted mandatory conciliation
proceedings. However, the same did not result in an amicable
settlement between the parties and caused the issuance of an order for
the simultaneous filing of position papers.

ISSUES
1. WHETHER OR NOT RESPONDENTS CAN BE HELD LIABLE FOR
THE UNDERPAID SALARY AND OTHER MONETARY CLAIMS
OF THE COMPLAINANTS.

2. WHETHER OR NOT COMPLAINANTS’ DECLARATION (FINAL

EXIT) BARS RECOVERY OF THEIR MONETARY CLAIMS.

3. WHETHER OR NOT COMPLAINANTS WERE UNDERPAID.

4. WHETHER OR NOT COMPLAINANTS ARE ENTITLED TO

OVERTIME PAY.

5. WHETHER OR NOT THE DEDUCTIONS FOR TRAFFIC

VIOLATIONS WERE PROPER.

6. WHETHER OR NOT NOMINAL, EXEMPLARY AND MORAL

DAMAGES.

DISCUSSION
FIRST ISSUE: AL ASSAL MANPOWER, INC. IS SOLIDARILY LIABLE
FOR THE UNDERPAID SALARIES AND OTHER MONETARY CLAIMS
OF COMPLAINANTS.
A recruitment agency is solidarily liable for the unpaid salaries of
a worker it recruited for employment with a foreign principal. Section
10, Rule V of the Implementing Regulations of the Labor Code provides:
Before recruiting any worker, the private employment agency shall
submit the following documents: xxx (2) Power of the agency to sue and
be sued jointly and solidarily with the principal or foreign-based
employer for any of the violations of the recruitment agreement, and the

5
contract of employment. (M.S. Catan Placement Agency v. National Labor
Relations Commission, G.R. No. 77279, April 15, 1988)
The Honorable Supreme Court has, time and again, ruled that
private employment agencies are held jointly and severally liable with
the foreign-based employer for any violation of the recruitment
agreement or contract of employment. This joint and solidary liability
imposed by law against recruitment agencies and foreign employers is
meant to assure the aggrieved worker of immediate and sufficient
payment of what is due him. This is in line with the policy of the state to
protect and alleviate the plight of the working class. (Santosa Datuman
v. First Cosmopolitan Manpower and Promotion Services, Inc., G.R. No.
156029, November 14, 2008)
It is therefore most respectfully submitted by the Complainants
that the liability of the principal Naqel Express may be enforced to the
full extent against the Al Assal Manpowerm Inc.

SECOND ISSUE: COMPLAINANTS’ DECLARATION (FINAL EXIT) DOES

NOT BAR RECOVERY OF THEIR MONETARY CLAIMS
From the foregoing facts, evidently the DECLARATION (FINAL
EXIT) should not bar the recovery of Complainants monetary claims for
the same were not even voluntarily executed by the Complainants. The
signing of the DECLARATION (FINAL EXIT) was dependent on the fact of
whether they can return to the Philippines or not, because it was only
after the signing of the same that their plane tickets and exits visas will
be issued by the principal (Naqel Express). The Complainants were left
with no other choice but to sign the DECLARATION for they wish to
return to the Philippines and to discontinue working under the poor
and inequitable working conditions.
Generally, the law looks with disfavor on quitclaims and releases
by the employees who are inveigled or pressured into signing them by
unscrupulous employers seeking to evade their legal responsibilities
and to frustrate just claims of employees. (JMM Promotions and
Management, Inc. v. Court of Appeals, G.R. No. 139401, October 2, 2002)
Quitclaims executed by laborers are commonly frowned upon as
contrary to public policy and ineffective to bar claims for the full
measure of the worker's legal rights and the acceptance of benefits
therefrom does not amount to estoppels. (R & E Transport, Inc. v. Latag,
G.R. No. 155214, February 13, 2004)
The reason is laid down in Lopez Sugar Corporation v. Federation
of Free Workers:
The reason is plain. Employer and employee, obviously, do not
stand on the same footing. The employer drove the employee to the

6
wall. The latter must have to get hold of money. Because, out of job, he
had to face the harsh necessities of life. He thus found himself in no
position to resist money proffered. His, then, is a case of adherence, not
of choice. Renuntiatio non praesumitur (G.R. Nos. 75700-01, August 30,
1990).
Courts must undertake a meticulous and rigorous review of
quitclaims or waivers, more particularly those executed by employees.
This requirement was clearly articulated by Chief Justice Artemio V.
Panganiban in Land and Housing Development Corporation v. Esquillo:
Quitclaims, releases and other waivers of benefits granted by laws
or contracts in favor of workers should be strictly scrutinized to protect
the weak and the disadvantaged. The waivers should be carefully
examined, in regard not only to the words and terms used, but also
the factual circumstances under which they have been executed.
(G.R. No. 152012, September 30, 2005,)
The waiver or declaration in the case at bar is couched in general
language and does not provide for a detailed account of the entitlements
of the Complainants. The factual circumstances surrounding the
execution of the Declaration would show that it was not voluntarily and
freely execute the document.
To reiterate, the Complainants were left with no other choice but
to sign the DECLARATION as they wanted to return to the Philippines
and to discontinue working under the poor and inequitable working
conditions.
Complainants submit that the Declaration is a contract of
adhesion which should be construed against the employer. An
adhesion contract is contrary to public policy as it leaves the weaker
party—the employee—in a "take-it-or-leave-it" situation. Certainly, the
employer is being unjust to the employee as there is no meaningful
choice on the part of the employee while the terms are unreasonably
favorable to the employer.
Thus, the Declaration purporting to be a quitclaim and waiver is
unenforceable under Philippine laws in the absence of proof of the
applicable law of Saudi Arabia.
In Edi-Staff Builders International, Inc. v. National Labor Relations
Commission, the Supreme Court outlined the requirements for a valid
and enforceable waiver, said agreements should contain the following:
1. A fixed amount as full and final compromise settlement;
2. The benefits of the employees if possible with the corresponding
amounts, which the employees are giving up in consideration of
the fixed compromise amount;

7
 3. A statement that the employer has clearly explained to the
employee in English, Filipino, or in the dialect known to the
employees—that by signing the waiver or quitclaim, they are
forfeiting or relinquishing their right to receive the benefits which
are due them under the law; and
4. A statement that the employees signed and executed the
document voluntarily, and had fully understood the contents of
the document and that their consent was freely given without any
threat, violence, duress, intimidation, or undue influence exerted
on their person.
It is advisable that the stipulations be made in English and
Tagalog or in the dialect known to the employee. There should be two
(2) witnesses to the execution of the quitclaim who must also sign the
quitclaim. The document should be subscribed and sworn to under oath
preferably before any administering official of the Department of Labor
and Employment or its regional office, the Bureau of Labor Relations,
the NLRC or a labor attaché in a foreign country. Such official shall assist
the parties regarding the execution of the quitclaim and waiver. (G.R.
No. 145587 October 26, 2007).
From the foregoing, the Complainants submit that their claims
against Respondent should not be barred by their execution of the
DECLARATION (FINAL EXIT) as the same are not validly executed and
likewise unenforceable in the Philippines.

THIRD ISSUE: UNDERPAYMENT OF FOOD ALLOWANCE

The Contract signed by the Complainants on February 17, 2015 in
Davao City reflected a SAR 300.00 worth of Food Allowance which will
be added to their basic salary. However, upon arrival in Manila on
March 15, 2015, they were made to sign another Contract which
showed a SAR 200.00 worth for Food Allowance, leaving a difference of
SAR100.00.
Complainants respectfully submit a computation (ANNEX “I-1”, “I-
2”, “I-3” and “I-4”) of the underpayment of the salary of the
Complainants based on the February 17, 2015 Employment Contract
signed in Davao City.
As a rule, stipulations in an employment contract not contrary to
statutes, public policy, public order or morals have the force of law
between the contracting parties. (Art. 1306 of the Civil Code; Lagunzad
vs. Soto, G.R. No. L-32066 August 6, 1979)
The first contract signed in Davao City is the Contract which has
the force of law between the parties because it bears the appropriate

8
seal and certifications by the concerned government agencies in the
Philippines and in the Kingdom of Saudi Arabia.

FOURTH ISSUE: OVERTIME PAY

As to the overtime pay or payment for work beyond the regular
working hours was specifically provided in the employment contract,
viz:
xxx
6 – Overtime Pay:
For work over regular working hours: 1,5
For work designated rest days and holidays as per Saudi Law
The contract itself does not provide for a limit of allowable
overtime which an employee can render. As a matter of fact, the
Complainants were made to work for more than eight (8) hours and yet
NAQEL EXPRESS will only pay for the three (3) hours excess of the
regular working hours. This practice is greatly prejudicial to the
Complainants.
Therefore, the Complainants respectfully submits for the
consideration of the Honorable Labor Arbiter the aforementioned Trip
Plan Report schedule which was made part of this Position Paper as
ANNEXES“C-1”, “C-2”, “C-3” and “C-4”) which will show that indeed
Complainants were employed, permitted and suffered to work for more
than the regular working hours.

FIFTH ISSUE: DEDUCTIONS FOR TRAFFIC VIOLATIONS WERE NOT

PROPER
The deductions were not proper and lacks legal basis. While there
is a clause in the employment contract regarding compliance to
company rules and pertinent laws of the Kingdom of Saudi Arabia, it
does not stipulate for any fines or salary deductions in cases of non-
compliance.
Clause 17 of the Employment Contract provides:
17 – The employee shall observe employer’s company
rules and abide by the pertinent laws of the Kingdom of
Saudi Arabia and respect its customers and traditions.
This clause is not an authority for the Respondents to deduct fines
in cases of violation of the laws of KSA; nor does the same constitute as

9
consent on the part of the Complainants for a deduction in cases of
violations.
The employment of general terms in the statements should be
resolved in favor of the Complainants. It is a settled rule that in the
interpretation of labor contracts, the rule is, all doubts in the
construction of labor contracts should be resolved in favor of the
working class. This is in accordance with Article 1702 of the NCC,
which directs that in case of doubt, all labor legislation and all
labor contracts shall be construed in favor of the safety and decent
living for the laborer. The rationale behind this rule is that labor
contracts are not ordinary contracts. The relation between capital and
labor are not merely contractual in that the parties do not have
complete freedom as to the terms of their relationship. Labor contracts
are so impressed with public interest that labor contracts must yield to
the common good. (Article 1700 of the Civil Code, Servidad v. National
Labor Relations Commission, G.R. No. 128682 March 18, 1999)
Moreover, applying by analogy the rationale for the prohibition
against wage deductions under Article 113 and 114 of the Labor Code, it
is the inclination of our courts to to strictly construe the same against
the employer because evidently, the posting of cash bonds and the
making of deductions from the wages would inarguably impose an
additional burden upon the employees.
Evidently, the deductions for traffic violations have no basis under
the employment contract nor under our laws which are deemed to be
written in the employment contract as well. While the parties were free
to stipulate on the terms and conditions of the employment contract,
provided that they are not contrary to statutes, public policy, public
order or morals, they did not stipulate as to any deductions for
violations of the company rules as well as the laws of the Kingdom of
Saudi Arabia. It is also worth noting that the company rules and
regulations were not made known to the Complainants prior or upon
their engagement or employment.

FOURTH ISSUE: NOMINAL, EXEMPLARY AND MORAL DAMAGES

The Complainants are entitled to Moral and Exemplary Damages
in this case. Well settled is the policy that the employee is entitled to
moral damages when the employer acted a) in bad faith or fraud; b) in a
manner oppressive to labor; or c) in a manner contrary to morals, good
customs, or public policy. (Montinola v. Philippine Airlines, G.R. No.
198656 , September 8, 2014)
Bad faith "implies a conscious and intentional design to do a
wrongful act for a dishonest purpose or moral obliquity." (Laureano

10
Investments and Development Corp. v. Court of Appeals, G.R. No. 100468,
May 6, 1997)
The bad faith of respondent was showed when it made the
Complainants sign two (2) contracts of employments, one which
contains a food allowance less than the other. To make matters worse,
the second employment contract which contains a lesser rate for the
food allowance which should be part of the Complainants’ basic salary
was a mere photocopy and the certifications and seal by the appropriate
government agencies are dated a year earlier than the date which they
actually signed the contract. This was a conscious and intentional design
to do a wrongful and dishonest act on the part of the respondent Al
Assal Manpower, Inc.
Likewise, the Complainants are entitled to exemplary damages.
Under Article 2229 of the Civil Code, "[e]xemplary or corrective
damages are imposed, by way of example or correction for the public
good, in addition to the moral, temperate, liquidated or compensatory
damages." As this court has stated in the past: "Exemplary damages
are designed by our civil law to permit the courts to reshape
behaviour that is socially deleterious in its consequence by
creating negative incentives or deterrents against such behaviour."
(Montinola v. Philippine Airlines, G.R. No. 198656 , September 8, 2014)
The respondent is engaged in a business which is imbued with
public interest. Any conscious and intentional design to do a wrongful
act for a dishonest purpose or moral obliquity for purposes of profit
should be penalized as to set an example to all those engaged in a
similar business and to prevent further damage to unsuspecting
employees recruited.

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed
of this Honorable Labor Arbiter, that decision be rendered, to wit:
1. Ordering the Respondents to pay the Complainants the
difference of SAR 100.00 Food Allowance as appearing
on the Contract of Employment;
2. Ordering the Respondents to pay the correct overtime
pay based on the hours that they were permitted and
suffered to work beyond the regular working hours as
provided by the contract of employment;
3. Furthermore, it is likewise prayed unto the Honorable
Labor Arbiter to order the Respondent to pay the herein
Complainants the amount of Php 50,000.00 for each as
11
 moral damages and the amount of Php 25,000.00 each
as exemplary damages.
Other reliefs just and equitable under the premises are also
prayed for.

RESPECTFULLY SUBMITTED.

Davao City, Philippines, June 30, 2017.

JESSIE V. MONQUIL GREGORY N. DELA PEŇA

Complainant Complainant

ELMAR T. ZABATE NOLI C. MORALES

Complainant Complainant

Assisted by:

ATENEO LEGAL AID SERVICES

Counsel for the Complainants
2/F Dotterweich Hall
Jacinto Street, Davao City
Tel. No. (082) 227-7460; Fax 225-0770

ATTY. MANUEL P. QUIBOD

Roll No. 33499
PTR No. 7458862 B; 1-03-17, D.C.
IBP Life Member Roll No. 00996
MCLE Exemption No. V-001179, 02-22-16, M.M
For the 5th Compliance
(valid for 02-11-16 until 04-04-19)

12
 ATTY. SIGRID KIM G. MIER
Roll No. 67038
IBP No. 005790 – 05/19/2017 – Pasig City
PTR No. 8808913 – 05/26/2017 – Davao City
TIN No. 701-038-110

By:

ATTY. SIGRID KIM G. MIER

Roll No. 67038
IBP No. 005790 – 05/19/2017 – Pasig City
PTR No. 8808913 – 05/26/2017 – Davao City
TIN No. 701-038-110

13
Republic of the Philippines)
City of Davao …….…….) S.S.

VERIFICATION AND CERTIFICATION

We, JESSIE T. MONQUIL, NOLI C. MORALES, ELMAR T. ZABATE and

GREGORY DELA PEŇA, of legal ages, Filipinos and residents of Davao Occidental and
Davao City respectively, Philippines, respectively, after having been sworn in
accordance with law, hereby depose and state that:

1. We are the complainants in the above-entitled case;

2. We have caused the preparation and the filing of the Verified Position
Paper and its contents are true and correct of our own knowledge and
belief;
3. We have not commenced any other action or proceeding, involving the
same resolution or issues in any court, tribunal, body or agency and that
to the best of our knowledge, no such other action or proceeding is
pending in any other court, tribunal, body or agency. Should we hereafter
learn that a similar action or proceeding had been filed or is pending
before another tribunal, court, body or agency, we undertake to report
that fact to the Honorable Office within five (5) days there from.

IN WITNESS WHEREOF, we have hereunto set our signatures this 30th day of
June 2017 in the City of Davao, Philippines.

JESSIE V. MONQUIL GREGORY N. DELA PEŇA

Affiant Affiant
_________________________ _________________________

ELMAR T. ZABATE NOLI C. MORALES

Affiant Affiant
_________________________ _________________________

SUBSCRIBED AND SWORN to before me this 30th day of June in Davao City,
Philippines.

Doc No.
Page No.
Book No.
Series of 2017

14