Reply Lavadia.doc

Republic of the Philippines Department of Labor And Employment NATIONAL LABOR RELATIONS COMMISSION National Capital Region Quezon City HERNANIE CABUYAO LAVADIA, Complainant, - versus - Case No. NCR-05-07508-17 Arbiter: JOEL S. LUS
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  Republic of the Philippines Department of Labor And EmploymentNATIONAL LABOR RELATIONS COMMISSION National Capital RegionQuezon City HERNANIE CABUYAO LAVADIA Complainant, - versus - Ca!e No NCR#$%#$&%$'#(&  Arbiter: )OEL S LUSTRIA*ORTUNE MEDICARE INC  + ,IL*REDO CABAN-ON Respondents. x----------------------------------------------x RE.LY TO RES.ONDENTS/.OSITION .A.ER COMPLAINANT  , through undersigned counsel, unto this onorable!ffice, in reply to respondents Position Paper, respectfully alleged:#hat respondents ad$itted the allegations in co$plainant s Position Paper but raised this issue: 1. Co$plainant is not entitled to their %ic& 'eave and(or )acation 'eaveconversions* A R - U M E N T S  As per the letter dated +anuary , ./ the President of 0ortune1edicare, 2nc* 3r* Alfonso R* %ahagun infor$ing the 3!'4 as regards the statusof the co$pany and its intention to retrench its e$ployees, $ar&ed as Annex 56to 7it:  “In this time of difficulty, the company assures every employee concerned or part of said retrenchment program of proper compensation of its benefits inaccordance with the company employees hand book and/or existing labor laws.  2n this case, the President &ne7 for the fact the existence of the co$pany shandboo&, 7hereby they it ta&e into account the co$pensation benefits 7hichits e$ployees 7ere entitled, thus the co$pany is no7 estopped to deny theexistence of such right*#o put e$phasis, the handboo& of the co$pany noted that Annex 8888 0inancial state$ents for .9 and ., $erely self serving as no signature of the accountant 7as indicated*  Asian Alcohol Corporation v. National Labor RelationsCommission .RAYER,HERE*ORE , pre$ises considered, co$plainant respectfully prays tothis onorable !ffice that ;udg$ent be rendered: 1. !rdering the herein respondents to pay herein co$plainant the $onetarye<uivalent of his unused convertible sic& leave credits= and*!rdering the herein respondents to pay the corresponding Attorney s fees= All other ;ust and e<uitable reliefs under the circu$stances are li&e7iseprayed for* 888888888, ./*1anila for Quezon City*3epart$ent of +ustice .UBLIC ATTORNEY/S O**ICE  Man0la D0!tr01t Off01e > th  0loor ?illia$ @odino uildingB. A* )illegas %treet, 4r$ita, 1anila#el No* >..-/y : Atty DYANNE O )OA2UIN 2P N!* .9, 0ebruary 9, ./Roll of Attorney No* B>/1C'4 Co$pliance No* v -...9>DCopy furnished: Atty )OSE DOMA DE LEON Counsel for Respondent> th  0loor Citystate Centre/. %ha7 lvd*, Pasig City


Aug 6, 2018


Aug 6, 2018
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