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Answer
Answer
SUSAN RADOC,
Complainant.
ANSWER
indicated in her complaint dated February 7, 2006 filed before this Honorable
Office : (a.) that she is the legal wife of the respondent (b) that they got married
on January 22, 1999 and (c) that she gave birth to their daughter, Shekainah Yari
Dawh Radoc
her complaint for being false, baseless, inaccurate, misleading and/or not
devoid of factual and legal bases, the truth being those alleged in the special
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SPECIAL AND AFFIRMATIVE DEFENSES
indicated in the Seafarer Information Sheet dated June 11, 2003 attached to the
complaint that he is single. The fact remains that it was not the respondent who
prepared said Seafarer Information Sheet and later filed it at the POEA but it was
prepared by the manning agency. Nowhere in said document can one find
agency who prepared said document. Due to the fact that a third person
slips which were signed by the respondent. Copies of the Allotment Slips are
hired as junior seaman for the vessel SPLENDOUR OF THE SEA. However, he
was actually hired for the vessel RADIANCE OF THE SEAS wherein he was on
board from September 7, 2002 until April 5, 2003. A copy of pertinent portion of
made an integral part hereof as Annex C. Said seafarer information sheet did
not reflect accurate facts on the employment of the respondent with the manning
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agency since it contained information that are not consistent with the evidence
Information Sheet that was prepared and filed by the manning agency in order
this Honorable Office could have been the earlier version, to which respondent
her complaint will clearly reveal that what she has are only self-serving and
8. The Complaint in this case is bereft of any factual and legal basis
PRAYER
Honorable Office to dismiss the instant complaint for utter lack of merit.
Respondent prays for such other reliefs just and equitable under the
premises.
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Makati City for Mandaluyong City, March 29, 2006.
DENNIS R. GORECHO
PTR NO. 4195983E-Makati-Jan. 11, 2006
IBP NO. 671075-PPLM-Jan. 11, 2006
ROLL NO.44352
Copy Furnished:
Susan C. Radoc
Jagnaya, Jamindan
5808 Capiz