COMPLAINT

COMES NOW, the petitioner A together with the undersigned counsel to

this most honorable court, MOST RESPECTFULLY STATES THAT;
1. The Petitioner A was engaged as a General Manager of the Respondent,
Company B, with the following duties and responsibilities: (1) Project
Management, (2) Operations, Engineering and Maintenance
Management, (3) Finance and Administration, and (4) Design and Value
Engineering on October 05, 2001.
2. Petitioner was able to expand the company and increase its assets.
Indeed, in its Audited Financial Statements from 2010 to 2012, the
Company gained huge income.
3. Non-remittance of SSS, PAGIBIG and PHILHEALTH contribution, which
were deducted from the employees, was reported. This duty belongs to
the HR Department which the petitioner does not head.
4. Petitioner organized Corporation C as major stock holder, with the
consent of the Chairman of the Board of Directors. Respondent was
responsible for a Four Million worth of materials to Corporation C.
5. A requested for an early retirement by September 2014 which the
Chairman of Directors initially approved, but later on, advised her that
such approval is only provisional.
6. A expressed her objection, then she was dismissed from her service and
directed to answer a Notice to Explain.
7. The petitioner requested an extension of time to answer the notice but
Company B declined her request and dismissed her.

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of
this Honorable Court that judgment be rendered in favor of the petitioner and

that the petitioner must be reinstated with claim of backwages and other
money claims.
COMPLAINT

COMES NOW, the petitioner, Company B, together with the

undersigned counsel to this most honorable court, MOST RESPECTFULLY
STATES THAT;
1. On October 05, 2001, the Respondent Company B engaged A as their
General Manager with the following duties and responsibilities: (1)
Project Management, (2) Operations, Engineering and Maintenance
Management, (3) Finance and Administration, and (4) Design and Value
Engineering.
2. In a recent management audit, it was found out that the Audited
Financial Statements of 2010 to 2012 indicates critical status of the
company, which A failed to refer to the board of directors. Furthermore,
A misrepresented the said financial report which projected positive
results, meanwhile found to be inaccurate as the management audit in
2013 that shows loss.
3. Also, there were findings of non-remittance of SSS, PAGIBIG and
PHILHEALTH contribution of employees which are deducted from them.
This resulted to As criminal prosecution.
4. Conflict of Interest between A and Company B arose when A organized
C Corporation as major stock holder which Company B owes FOUR
MILLION worth of oversupply of materials ordered by A.
5. Subsequently, A requested for early retirement which the Chairman of
Board of Directors initially approved provisionally subject to the boards
confirmation, A objected and dismissed her service. Company B sent A
a notice on gross misconduct, which she was asked to answer. A sought
two extensions of time for 15 days to respond; the first one was granted
while the second was declined.

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of
this Honorable Court that judgment be rendered in favor of the petitioner and
that the petitioner must be reinstated with claim of backwages and other
money claims.