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HON. TUNGKUH B. HANAPI and
HON. ABDUL-AZIZ C. HANAPI
Barangay Kagawad/Complainant,
- FOR
DISHONESTY , GROSS
NEGLECT OR DERELICTION
OF DUTY, ABUSE OF
AUTHORITY AND
VIOLATION OF IRR RA
8184
x--------------------------------------------------x
ANSWER
COMES NOW, the undersigned counsel for Respondent ENGR.
GILBERT B. SAN ANTONIO in the above-entitled administrative case and
to this Honorable Commision most respectfully states that:
Intellectual Property code recognizes that the intellectual-property rights include the
protection of undisclosed information that requires courts to adopt measure to protect the
manufacturing and business secrets of a company in a patent infringement case;
within one hundred twenty (120) days after the last examination day unless
extended by the Commission; and, subject to approval by the Commission
determine the appropriate passing general rating if not provided for in the law
regulating the profession.
COMMITTED
UNPROFESSIONAL
AND/OR
11.
In his allegation that ENGR. SAN ANTONIO stole Vital
Company Files and Operational Manuals has no factual basis. As the
production Manager the herein respondent is fully equipped, with
respect to the Operational Manuals because the management has
provided him the same since it has something to do with ENGR. SAN
ANTONIO line of work to know the Operation and the Process flow to
fully understand the processing Operation and to effectively
dissiminate the Opeartional instruction/information to his subordinates
(e.g. processing supervisor, foremens and line checker).How can you
effectively work as production manager without fully understanding
the Operational Manuals in the factory?
12.
13.
the
integrity
of
substantial
evidence.
Citing
15. In the instant case, the instant complaint was solely anchored in the
self serving allegations of Complainant ENGR. DE SOSA. No other
testimonies, concrete and circumstantial evidences that would
corroborate his allegations. There can be no mistaking that
complainant would not but be motivated by malicious and unlawful
intent to harass, oppress, and cause damage to herein respondent;
16. Furthermore, the herein respondent is also assigned/task to escort,
and answer the question of BFAR INSPECTOR and the EU
INSPECTION TEAM, everytime they conduct the HACCP SYSTEM
AUDIT AND RENEWAL INSPECTION for it is their corporate
commitment to manufacture and distribute premium quality canned
sardines and impose strict regulations on sanitation and hygiene;
17. Aside from that, in compliance with the requirements of the Board of
Mechanical Engineering for Professional Mechanical Engineer (PME)
Licensure under RA 8495, a copy of which was submitted to PRC.
18. As noted all allegation are only content of the Engineering Report
INTRODUCTION & BASIC COMPANY INFORMATION. These are
the information required by Board of Mechanical Engineers to be
included in the Engineering Report. But the most vital of the report is
in Chapter TWO (ENGINEERING REPORT) comprises the Design
Calculation which was carefully computed to meet the design;
19. After completing the Professional Development Course on 24th day of
July 2010 ENGR. SAN ANTONIO is already prepared to proceed with
his Engineering Report the format of which is provided by the Board
of Mechanical Engineers (BME) for PME Licensure under R.A. 8495.
Attached herein is the PSME Certificate of Completion as ANNEX
C and Engineering Report (Suggested Format) as ANNEX D;
20. That the Engineering Report was done intended for the benefit of
Universal Canning Inc. sometime in the month of September 2011,
even MRS. ANITA KAW, the owner of UCI, was aware when she
personally allowed him to submit the hard bound of his Engineering
Report with PRC IX last September 23, 2013 which is the due date
for its submission with one month extension. And then ENGR. DE
SOSA approved the Engineering Report when he affixed his
signature in the Engineering Report of ENGR. SAN ANTONIO.
Actually when he affixed his signature on the space provided for his
name, I questioned him regarding his licensed registration date which
he did not put and told me in this wise dont worry because it is not
important anymore. What is important is you can show the
computation on your Engineering Report. Attached herewith is the
Certificate of Experience of ENGR. SAN ANTONIO as ANNEX E.
In fact, ENGR. RODEL A. TULANG came to know that ENGR. DE
SOSA already signed the Engineering Report of ENGR. SAN
ANTONIO he asked a favor to also let ENGR. DE SOSA signed his
Cerificate of Experience; A copy of the Certificate of Experience and
Affidavit ENGR. RODEL A. TULANG of attesting to the foregoing
facts is hereto attached as ANNEX F and ANNEX G.
21. With respect to the allegation that ENGR. GILBERT B. SAN
ANTONIO simply copied his report from _________this is considering
that the Board of Mechanical Engineer has thoroughly reviewed his
engineering report even at its inception when he presented the title of
his report in facthe BME made suggesttion to change the title from
Other relief as are just and equitable under the premises are likewise prayed for
City of Zamboanga, for Manila ________________________.
Copy of this VERIFIED POSITION PAPER was sent to the Honorable Office via LBC EXPRESS because of
the impracticability of personal service. A copy of the same was furnished to the Complainant at her last known
address in Zone 3, KM. 6, Mampang, Zamboanga City, Philippines.