REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF LABOR AND EMPLOYMENT

NATIONAL LABOR RELATIONS COMMISSION
NATIONAL CAPITAL REGION
BANAUE, QUEZON CITY

RENATO DALORE,Complainants, NLRC NCR Case No. 07-11147-09-versus-JEN

EXPRESS TRUCKING AND/OR JUSTO LIM
,Respondents.x---------------------------------------------------x

REPLY POSITION PAPER

COME NOW the respondents, through counsel, and to this Honorable Office, as Replyto the
complainants Position Paper, most respectfully state:
I.
Contrary to the insinuation of the complainant in the Preparatory statement of hisPosition
Paper. The complainant may have mistakenly entertained the idea that in every labor
dispute, even if the employees claims or complaints are false and baseless, the same will
beresolved in the workers favor. He has forgotten that the employer has also right and
interest thatdeserves respect and protection:While the Constitution is committed to the
policy of social justiceand the protection of the working class, it should not be supposedthat
every labor dispute will be automatically decided in favor of labor. Management also has its
own rights which, as such, areentitled to respect and enforcement in the interest of simple
fair play.Out of its concern for those with less privileges in life, this Court hasinclined more
often than not toward the worker and upheld his causein his conflicts with the employer.
Such favoritism, however, has not blinded us to the rule that justice is in every case for the
deserving, to be dispensed in the light of the established facts and the applicablelaw and
doctrine.(Enriquez v. Bank of Philippine Islands 544 SCRA593, 2008)