Republic of the Philippines)

Baguio City ) s.c

x------------------------------------x

AFFIDAVIT / POSITION PAPER

I, JAIME P. SANGLAY, of legal age, single, Filipino and a resident of

Central West, No. 3, Bangar, La Union, under oath depose and state, that:

1. I filed a complaint for Illegal dismissal, monetary claims, moral and

exemplary damages plus reasonable Attorney’s fees against my former
employer Philippine Rabbit Bus Lines Inc. as represented by its owner
Natividad P. Nisce with office address at Governor Pack Road, Baguio City
at the National Labor Relations Commission, Regional Arbitration Branch,
Cordillera Administrative Region (NLRC – RAB - CAR) docketed as NLRC
Case No. 08-0423-10);

2. I worked for the above company as Bus Conductor plying the route of
Baguio City to Manila and vice-versa for almost sixteen (16) years. My
latest salary was Six Hundred Seventy Seven Pesos (P677.00) per trip that
could be done in a day;

3. On July 28, 2010, I was handed my Notice of dismissal for allegedly

collecting fares without issuing tickets to two (2) passengers on June 19,
2010 and for a single passenger on June 29, 2010;

4. I was forced to admit the above incident when I was interrogated inside
respondent’s office during the administrative hearing and my reason is
that I used the alleged amount of money collected for washing the
expenses of the bus;

Page | 1
5. My admission was not voluntary as I was placed under preventive
suspension immediately after the alleged incidents and I needed to work as
my job is my family’s only source of income;

6. After being placed under preventive suspension, I had to do all other

means just to get back to work for my family’s sustenance. I was in a
dilemma on what to do and I was advised by my co-workers to just admit
the allegations against me even if it was false in order for me to get back to
work the soonest possible time. So I wrote management a concocted letter
and admitting to have committed the above acts and begging management
to reconsider my being dismissed from service but my plea fell on deaf ears
when I was issued a Notice of dismissal;

7. Respondents should be held liable in accordance with Article 279 of the

Labor Code of the Philippines, as amended;

8. By reason likewise of the insensitivity of the respondents of my labor

rights as an employee, I suffered sleepless nights and besmirched
reputation for which reason respondents should be held liable for
reasonable moral damages;

9. To teach respondents a lesson so that the same should not be repeated

for the good of the public, respondents should be assessed reasonable
exemplary damages;

10. Since I was forced to engage the services of counsel to protect my

interest, respondents should also be made liable for attorney’s fees; and

11. I am executing this affidavit to attest to the truthfulness of the above

narration of facts and for purposes of supplementing the complaint for
illegal dismissal which I filed against the respondents.

Page | 2
 Affiant further says none.

IN WITNESS WHEREOF, I hereunto set my hand this 17 th day of

December 2010 at Baguio City, Philippines.

JAIME P. SANGLAY
TIN: 177-224-576-000

SUBSCRIBED and SWORN to before me in Baguio City, Philippines

this 17th day of December 2010 by the above affiant who is personally
known and identified by me to be the same person who freely and
voluntarily executed the above affidavit.

WITNESS MY HAND AND SEAL

Doc. No. ___; Milton L. Balagtey

Page No. ___; Notary Public
Book No. XX; until December 31, 2011
Series of 2010 PTR No. 2657119; 01-08-10; B.C
IBP No. 806002; 01-08-10;
B.C

Copy furnished:

Atty. Juan B. Valdez

Counsel for the respondents
5th Flr. Baguio Centermall,
Baguio City

Page | 3