Republic of the Philippines
NATIONAL LABOR RELATIONS COMMISSION
Regional Arbitration Branch
Cordillera Administrative Region
2nd Flr., Manongdo Bldg., No. 17 Private Rd.,
Magsaysay Ave., Baguio City
REMIGIO P. VICENTE and
BALDO GARRY B. BACBAC,
Complainants,
-versus- NLRC CASE No. RAB-CAR –
12-0432-11
CAMP JOHN HAY DEVELOPMENT
CORP. and ROBERT SOBREPENA,
Respondents,
x-------------------------------------------------x
(Amended)
COMPLAINT
Complainant/s most respectfully state, that:
Name of complainant/s 1. REMEGIO P. VICENTE
2. BALDO GARRY B. BACBAC
Age 1. 50
2. 38
Status 1. Married
2. Married
Sex 1. Male
2. Male
Address: 1. PA 182-C Upper Wangal, La Trinidad, Benguet
2. 124 Atok Trail, Baguio City
Position 1. Plant Operator/STP Operator/Utilities
2. Plant Operator/STP Operator/Utilities
Salary 1. Php. 7,826.00
2. Php. 7,826.00
Date Employed 1. February 10, 2003
2. April 2, 2003
Date Dismissed December 2, 2011 (for both complainants)
Name of respondent/s Camp John Hay Development Corporation and
Robert Sobrepena (owner/manager)
Address Camp John Hay, Baguio City
No. of Employees 300 +
Work Schedule Shifting basis
Frequency of Payment Every 15 days
Place of work Baguio City
Have you ever filed a similar case 1. Yes. DOLE-CAR
elsewhere 2. Yes. DOLE-CAR
Status Referred to the NLRC-CAR
Are you a member of a union 1. No
2. No
Is there an existing CBA No
CAUSES OF ACTION
1. Illegal dismissal, underpayment of separation pay, moral and exemplary damages,
and reasonable Attorney’s fees.
PRAYER
1. Payment of full backwages, separation pay in lieu of reinstatement, moral and
exemplary damages, and reasonable Attorney’s fees.
Other relief just and equitable under the premises.
Baguio City, Philippines, January 10, 2012.
REMEGIO P. VICENTE BALDO GARRY B. BACBAC
(Complainant) (Complainant)
VERIFICATION / CERTIFICATION
We, REMEGIO P. VICENTE and BALDO GARRY B. BACBAC, under oath declare,
that:
1. We are the complainants in the above entitled case; we caused the
preparation of the foregoing complaint; and we have read the same and
all the allegations therein are true and correct in our own personal
knowledge and based on authentic records and documents;
2. Except to that case which we filed at the DOLE-CAR which was referred
to this Honorable Office, we do not know of any pending case involving
the same parties and cause of action in any tribunal be it the Supreme
Court, Court of Appeals or any other court or quasi-judicial body; and we
undertake to inform this Office of any pending case involving the same
issue and parties within five (5) days from knowledge should there be
any.
IN WITNESS WHEREOF, I have hereunto set my hand this ___ day of January 2012, in
Baguio City, Philippines.
REMEGIO P. VICENTE BALDO GARRY B. BACBAC
(Complainant/Affiant) (Complainant/Affiant)
Subscribed and Sworn to before me this ___ day of January 2012, in the City of Baguio,
Philippines, by the above named persons, personally known and identified by me based on
competent evidence to be the same persons who executed the foregoing affidavit, that they
acknowledge to me that their signature were voluntarily affixed by them in my presence; and
that they further declare that they executed this affidavit as their free and voluntary act and
deed.
WITNESS MY HAND AND SEAL
