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    Complaint de Leon

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    darabes0406
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    Complaint de Leon

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    complaint

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    complaint

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    Download as docx, pdf, or txt
    10 views2 pages

    Complaint de Leon

    Uploaded by

    darabes0406
    complaint

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
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    Republic of the Philippines

    DEPARTMENT OF LABOR AND EMPLOYMENT


    NATIONAL LABOR RELATIONS COMMISSION
    Regional Arbitration Branch
    Cordillera Administrative Region
    Baguio City

    LEO B. DE LEON,
    TONY B. GUILLAY, JR
    Complainants NLRC CASE NO. RAB-CAR 12-0427-11
    -versus-

    L.C MANPOWER EXPERTISE CORPORATION


    and ADELIO E. CARAGAN,
    Respondents
    x---------------------------------------------------------------x

    COMPLAINT
    Complaints respectfully state.
    Name (Age, Address Position (Actual and Date of Salary Rate
    Status, sex, Pre- Contract) Departure
    Contact No.)
    Leo B. De Leon Purok 18, POEA CONTRACT March 27, 700 SR-
    39, M,M St.,Patrick, Irisan operator, Agency 2011 contract;
    09276197927 Baguio city contract 1,575.00
    -Driver SR-
    Actual- Driver contract
    Tony B. Guillay c/o Leo B. De POEA Contract- March 27, 840 SR-
    Jr., 30, S, M Leon ( same Heavy Equipment 2011 actual;
    09291277312 above) Operator, 1,575.00
    Agency Contract SR-
    -Trailer/driver contract
    Actual-driver
    Date of Arrival: Dec. 2, 2011- (both complainant)
    Name of Respondent Agency: L.C Manpower Expertise Corporation
    Ground Floor, Unit 1081 and 1079-B Ramagi Bldg.
    Pedro Gil St., Paco, Manila
    Name of Owner/ President: Adelio F. Caragan
    Principle: Ad Harbi Trading and Contracting Company Ltd.
    Place of Work: K.S.A

    CAUSE OF ACTION
    I. Underpayment of Wages
    2. Illegal dismissal (constructive)
    3. Non-payment of salary
    Compliant pray for the following:
    Payment of salary differentials from SR 1,575.00 to SR 700 ( de Leon) and SR 840
    for Guillay; full back wages; and wages for (6) months.
    Other reliefs just and equitable are likewise prayed for.

    Done in the City of Baguio, this 6th day of December 2011

    TONY B. GULLAY JR. LEO B. DE LEON

    VERIFICATION

    We, Tony B. Gullay Jr. and Leo B. de Leon, being duly sworn to in accordance with law,
    state that:
    We are the complainant in the above- entitled case. We have cause the filing and
    preparation of this complaint and have read the contents thereof and declare the same
    to be true and correct.
    We further certify that we have not commenced any other action/ proceeding in
    any court, tribunal of agency involving the same issue and that there is no such pending
    case before the said court, tribunal or agency. If we should learn about the same, we
    shall report it to this office within (5) days from knowledge thereof.

    TONY B. GULLAY JR. LEO B. DE LEON


    Driver’s License No. A04-08-000983 SSS ID No. 01-08414404-8

    SUBSCRIBED AND SWORN to before me this 7 th day of December 2011, in the


    City of Baguio, Philippines.

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