Republic of the Philippines

NATIONAL POLICE COMMISSION

NORTHERN SAMAR POLICE PROVINCIAL OFFICE
Catarman, Northern Samar

PHILIPPINE NATIONAL POLICE

Administrative Case No.
Complainant, PRO8 AC Nr.
0005-0113-2020

-versus-

Patrolman Julius Deo S. Sosing

Respondent.
x------------------------------x

POSITION PAPER

COMES NOW, respondent through undersigned counsel and unto

this Honorable Office do hereby submits this POSITION PAPER in
compliance with the order of PMAJ JOSEPH AQUINO QUELITANO
Summary Hearing Officer of the Northern Samar Police Provincial Office.

FACTS OF THE CASE

On February 9 to March 2, 2019 the above-named respondent

while assigned at Silvino Lubos Municipal Police Station, NSPPO and
within the Disciplinary Jurisdiction of the Regional Director, PRO8,
without filing the necessary application for sick leave nor prior approval
from his superior incurred absences which totaled to twenty-two (22)
working days and was subsequently charged with this administrative
case for Grave Neglect of Duty due to absences without leave (AWOL)
violating Memorandum Circular 2016-002. Respondent received the
summons ordering him to submit an answer on January 27, 2020 and
herein respondent faithfully complied with this order.

DISCUSSION AND ARGUMENTS

That by way of affirmative defense, the respondent hereby admits

that he incurred absences but with legitimate reasons, the reason being
that the respondent has been suffering from a strain variation of a
dengue fever called chikungunya which took weeks of recovery. Attached
to this position paper are the affidavits of JULIANITA SOSING and FE
NALAZON marked as Annex “1” and Annex “2” respectively. These

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affidavits bolster the fact that Patrolman Julius Deo Sosing was just
staying at their residence and recovering from said illness.

It is also pointed out, that Patrolman Julius Deo S. Sosing is new to

the force. Hence, he is not yet fully aware of the processes to be followed
when such incidents occur. He, in all honesty, forgot to file a sick leave
application. Hence, he was charged administratively for absences without
the proper leave. Patrolman Sosing admits that he incurred absences but
he also humbly admits that as a new policeman he was unaware of the
processes to be followed when illness plagues them. Throughtout the
current administrative charge process, Patrolman Sosing pointed out
that he has submitted his medical certificate but forogot to follow it up
with an application for a sick leave, attached to his position paper is the
answer of Patrolman Sosing showing his eagerness to comply with
administrative process and his superiors, the answer is hereto marked as
Annex “3” and made as an integral part of this position paper.

It must also be taken into consideration that this is the first offense
of Patrolman Julius Deo S. Sosing. Hence, a penalty of dismissal is too
grave of a penalty for such honest inadvertence. A penalty of suspension
would suffice if Patrolman Sosing was remiss in filing the proper
document.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed upon

this Honorable office that the herein respondent be given a second
chance and that the charge for grave neglect of duty against him be
dropped for it is too severe of a penalty for a first offense or be meted
with a lower penalty other than dismissal from service.

The respondent also prays for such and other reliefs as may e
deemed just and equitable.

Catarman, Northern Samar, Philippines

February 13, 2020

ATTY. MIKHAEL O. SANTOS

547 A. Bonifacio St. Brgy. Kasoy
Catarman, Northern Samar
Roll of Attorneys No. 72577
IBP No. 113161 Jan. 11, 2020
PTR No. 4319752 Jan. 6, 2020

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REPUBLIC OF THE PHILIPPINES )
PROVINCE OF NORTHERN SAMAR ) S.S.
MUNICIPALITY OF CATARMAN )

VERIFICATION

I, JULIUS DEO S. SOSING, of legal age, single, and a resident of

Brgy. Paninirongan, Pambujan, Northern Samar, under oath, depose and
state:

1. That I am the respondent of the above-entitled case;

2. That I have caused the preparation of the foregoing position

paper;

3. That I have read and understood the same and that all the
statements therein are true and correct based on my own
knowledge and information and based on authentic documents
in my possession;

IN WITNESS WHEREOF, I have hereunto set my hand this

________ day of February 2020, at Catarman, Northern Samar,
Philippines.

JULIUS DEO S. SOSING

Affiant
PRC Criminologist I.D.
Reg. No. 0109970

SUBSCRIBED AND SWORN TO before me, this _______ day of

February 2020, in Catarman, Northern Samar, affiant exhibited his PRC
I.D. as a competent proof of his identity.

Doc. No._____
Book No._____
Page No._____
Series of 2020

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