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Republic of the Philippines

NATIONAL LABOR RELATIONS COMMISSION


Regional Arbitration Branch No. ______
[CITY]

_____________________, RAB ___ Case No.______________


Complainant,

-versus-

_____________________,

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

POSITION PAPER

COMPLAINANT by the undersigned counsel and unto this Honorable Labor Arbitration Office,
most respectfully submits this position paper and avers the following to wit:

THE PARTIES

The Complainant in this case is ____________, of legal age, [CIVIL STATUS], with residence
at _________________________ [ADDRESS] where he could be served with summons and other
legal processes of this Honorable Office.

The Respondent is _______________________, a business establishment owned by


_______ and managed by _____________, with business address at ___________________, where
the said establishment and representative could be served with summons and other legal processes of
this Honorable Office.

STATEMENT OF FACTS

[INDICATE THE FACTS HERE AS WELL AS SUPPORTING DOCUMENTS]

ISSUES

1. WHETHER _________________________ [STATE THE ISSUES]


2. WHETHER _________________________

FIRST ISSUE: [INDICATE THE FIRST ISSUE)

[DISCUSSION OF THE ISSUE. PROVIDE ARGUMENTS HERE WITH YOUR LEGAL BASIS]

SECOND ISSUE: [INDICATE THE SECOND ISSUE]

[DISCUSSION OF THE ISSUE. PROVIDE ARGUMENTS HERE WITH YOUR LEGAL BASIS]
PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Labor


Arbiter, that decision be rendered, to wit:

1. [PRAYER 1, corresponding to the first issue]

2. [PRAYER 2, corresponding to the second issue]

Other reliefs just and equitable under the premises are also prayed for.

RESPECTFULLY SUBMITTED.

[CITY] ___________; [DATE] _________________________.

[SIGNATURE]
[NAME OF COUNSEL] ___________
Counsel for [PLAINTIFF/DEFENDANT]
[ADDRESS] ______________
IBP Lifetime No. ____________; [CITY] _____________
PTR No. _______________; [DATE], [CITY]
Roll of Attorney No. _______________________
MCLE Compliance No. ____________________

Copy furnished through personal service:

[NAME OF COUNSEL] __________________


Counsel for the [PLAINTIFF/DEFENDANT]
[FIRM NAME] _______________
[ADDRESS] ________________

[USE THE FOLLOWING IF SERVICE IS NOT MADE PERSONALLY]

Copy furnished through registered mail:


[NAME OF COUNSEL] __________________
Counsel for the [PLAINTIFF/DEFENDANT]
[FIRM NAME] _______________
[ADDRESS] ________________
Registry Receipt No. ________
Post Office ________________
Date _____________________

EXPLANATION

The foregoing [DESIGNATION OF PLEADING, MOTION, ETC] _______________and its


attachment were served on [NAME OF COUNSEL] ________________ by registered mail instead of
personal service as counsel for [PLAINTIFF/DEFENDANT] [STATE REASON]
___________________.

[SIGNATURE]
[NAME] _________________

VERIFICATION

Republic of the Philippines )


City of _______________ ) s.s.

COMPLAINANT, after having been duly sworn in accordance with law, deposes and states
that:
1. He is the plaintiff in the pleading/document entitled _____________________
2. He has caused its preparation
3. He has read it and the allegations therein are true and correct of his own knowledge or
based on authentic records.

[SIGNATURE]
[NAME] _________________

SUBSCRIBED AND SWORN TO before me in the City of _______________ on this day of


[MONTH AND YEAR]_________________, affiant exhibiting before me his Government Issued ID no.
_______________ issued on [DATE}__________________ at [PLACE OF
ISSUANCE]_____________________.

[SIGNATURE]
[NAME]_______
Notary Public

Until [DATE]__________________
PTR No. [NUMBER] ____________
Issued at [PLACE]______________
On [DATE] ___________________

Doc. No.
Page No.
Book No.
Series of [YEAR] __________.

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