Republic of the Philippines

COURT OF APPEALS
City of Manila

________ DIVISION

JAIME S. DAITO, DOING BUSINESS

UNDER THE NAME AND STYLE, JEREMIE
CONSTRUCTION DESIGN AND
CONSULTANCY,
Petitioner,

CA-G.R. No. SP. No. ______

- VERSUS - FOR: CERTIORARI WITH
APPLICATION FOR ISSUANCE
OF TRO AND/OR WRIT OF
PRELIMINARY INJUNCTION

THE HONORABLE NATIONAL LABOR

RELATIONS COMMISSION (2ND DIVISION),
and DOMINGA LATURNAS FOR AND
IN BEHALF OF HER HUSBAND
UPRESINO W. LATURNAS (DECEASED),
Respondents.
x------------------------------------------------------------------------------------------------x

PETITION FOR CERTIORARI

Petitioner unto this Honorable Court most respectfully states

as follows:

NATURE OF THE PETITION

This is a Petition for Certiorari under Rule 65 of the 1997 Rules
of Civil Procedure seeking to set aside the following resolutions of the
National Labor Relations Commission (Second Division) in case
number NLRC LAC NO. 09-002910-17(4)/NLRC CN RAB-III-08-
2441-16:

a] Resolution promulgated on 29 September 2017 denying the

Memorandum of Appeal filed by Petitioner Jaime S. Daito
(Certified true copy of the assailed Resolution attached hereto
as Annex “A”); and
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JAIME S. DAITO PETITION FOR CERTIORARI
 b] Resolution promulgated on 29 November 2017 denying the
Motion for Reconsideration filed by Petitioner Jaime S. Daito
(Certified true copy of the assailed Resolution attached hereto
as Annex “B”).

THE PARTIES
Petitioner Jaime S. Daito (hereafter referred to as “Petitioner
Daito”) is the sole proprietor of Jeremie Construction Design &
Consultancy (hereafter referred to as “Jeremie Construction”).
Petitioner Daito is married, of legal age, Filipino citizen and with
residence and postal address at 0240-106 Brgy. Sta. Rosa 1 3019
Marilao, Bulacan where he may be served with notices and
processes of this Honorable Court.

Private Respondent Dominga Laturnas (hereafter referred to

as “Private Respondent Laturnas”) is of legal age, Filipino citizen,
widow of Upresino W. Laturnas (hereafter referred to “Deceased
Upresino”) and with residence and postal address at No. 26 Villa
Lourdes Loma de Gato, 3019 Marilao, Bulacan where she may be
served with notices and processes of this Honorable Court.

Public Respondent The Honorable National Labor Relations

Commission Second (2nd) Division (hereafter referred to as “NLRC”)
may be served with notices and processes of this Honorable Court at
PPSTA Building, 245 Banawe St, Quezon City, 1114 Metro Manila.

TIMELINESS OF THE PETITION

Under Rule 65 of the 1997 Rules of Civil Procedure, when any

tribunal, board or officer exercising judicial or quasi-judicial functions
has acted without or in excess of its or his jurisdiction, or with grave
abuse of discretion amounting to lack or in excess of jurisdiction, and
there is no appeal, or any plain, speedy, and adequate remedy in the
ordinary course of law, a person aggrieved may file a verified petition
for certiorari in the proper court within a sixty (60) – day period
reckoned from date of receipt of the judgment, order or resolution.

Notice of NLRC’s assailed Resolution promulgated on 29

November 2017 denying Petitioner Daito’s Motion for
Reconsideration was received on 11 January 2018. Therefore,
Petitioner Daito has until 12 March 2018 within which to file this
Petition.

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JAIME S. DAITO PETITION FOR CERTIORARI
 In this regard, Petitioner Daito is filing the instant Petition within
the 60-day reglementary period provided for under the 1997 Rules of
Civil Procedure.

STATEMENT OF FACTS
AND OF THE CASE

1] On 5 August 2016, Private Respondent Laturnas for and in

behalf of her husband, Deceased Upresino filed with the Labor
Arbitration Branch of the National Labor Relations Commission
(NLRC) in Pampanga a complaint against Petitioner Daito and
Jeremie Construction for money claims (specifically wage
differentials, 13th month pay, and service incentive leave pay)
alleging that Deceased Upresino was employed by Jeremie
Construction as a regular employee with the position of mason
continuously during period covering year 2009 until Upresino’s
untimely demised on 22 June 2016.

A copy of Private Respondent Laturnas’ Position Paper is

attached hereto as Annex “C.”

2] On 21 November 2016, Petitioner Daito filed his Position

Paper with the Labor Arbitration Branch of the NLRC in Pampanga.
A copy of his Position Paper attached hereto as “Annex “D.”

3] On 23 January 2017, Petitioner Daito and Private

Respondent Laturnas simultaneously filed with the Labor Arbitration
Branch their respective Replies to the aforestated Position Papers.
A copy of Petitioner Daito’s Reply to Position Paper attached hereto
as Annex “E.” Upon the other hand, a copy of Private Respondent
Laturnas’ Reply to Position Paper is attached hereto as Annex “F.”

4] On 6 February 2017, Petitioner Daito submitted his

Rejoinder to Complainant’s (Private Respondent Laturnas in this
case) Reply. A copy of which is attached hereto as Annex “G.”

5] On 12 May 2017, Hon. Labor Arbiter Roderick Q. Almeyda

(hereafter referred to as “Labor Arbiter Almeyda”) promulgated a
Decision the dispositive portion of which reads as follows:

“WHEREFORE, judgment is hereby rendered ordering Jeremie

Construction (Jeremie Construction Design and Consultancy) and its
owner Jaime S. Daito to pay complainant Dominga Laturnas in behalf
of her deceased spouse Upresino Laturnas the following:

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JAIME S. DAITO PETITION FOR CERTIORARI
 1. Wage Differentials Php41,147.60
2. 13th Month Pay Php26,828.96
3. Service Incentive Leave Pay Php5,245.00
4. 10% Attorney’s Fees Php7,322.15

TOTAL - Php80,543.71

The rest of the money claims including moral and exemplary

damages are denied for lack of merit.

The attached computation sheet of the complainant’s

judgment awards shall form an integral part of this Decision.

SO ORDERED.

City of San Fernando, Pampanga, May 12, 2017.”

Copy of aforesaid Decision promulgated on 12 May 2017 is

attached hereto as Annex “H.”

6] The aforesaid Decision of Labor Arbiter Almeyda was

received by Petitioner Daito on 01 August 2017.

7] On 11 August 2017 or within the ten (10) – day reglamentary

period within which to appeal the aforesaid Decision of Labor Arbiter
Almeyda as provided for in Rule VI, Section 1 of the NLRC Rules of
Procedure, Petitioner Daito perfected an appeal with the NLRC.

Copy of Petitioner Daito’s Memorandum of Appeal is attached

hereto as Annex “I.”

8] Thereupon, Private Respondent Laturnas filed with the

NLRC her Answer to Petitioner Daito’s Memorandum of Appeal
(Annex “I”). A copy of Private Respondent Laturnas’ Answer is
attached hereto as Annex “J.”

9] On 18 September 2017, Petitioner Daito filed his Rejoinder

to Private Respondent Laturnas’ Answer to the Memorandum of
Appeal (Annex “J”). A copy of Petitioner Daito’s Rejoinder is
attached hereto as Annex “K.”

10] On 29 September 2017, the NLRC promulgated its first

assailed Resolution (Annex “A”) which was received by Petitioner
Daito on 27 October 2017. The dispositive portion of the assailed
Resolution reads as follows:

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JAIME S. DAITO PETITION FOR CERTIORARI
 “WHEREFORE, the appeal is DISMISSED. The Labor
Arbiter is AFFIRMED.

SO ORDERED.

Quezon City, Philippines.”

11] On 6 November 2017, Petitioner Daito moved for

reconsideration of the 29 September 2017 assailed Resolution
(Annex “A”) of the NLRC. A copy of Petitioner Daito’s Motion for
Reconsideration is attached hereto as Annex “L.”

12] On 29 November 2017, the NLRC resolved the Motion for

Reconsideration (Annex “L”) filed by Petitioner Daito by affirming its
assailed Resolution (Annex “A”) finding no cogent reason to depart
from its earlier findings.

Hence, the NLRC’s second assailed Resolution (Annex “B”),

the dispositive portion of which reads as follows:

“ACCORDINGLY, the instant Motion for Reconsideration

is hereby DENIED for lack of merit.

No further Motion for Reconsideration shall be

entertained.

SO ORDERED.

Quezon City, Philippines.”

13] Against the factual backdrop as narrated above and there

being no appeal nor any plain, speedy, and adequate remedy in the
ordinary course of law, this Petition for Certiorari with Prayer for
Issuance of Temporary Restraining Order and/or Writ of Preliminary
Injunction under Rule 65 of the Rules of Court.

STATEMENT OF ISSUES

I.

WHETHER OR NOT PUBLIC RESPONDENT NATIONAL LABOR

RELATIONS COMMISSION SERIOUSLY ERRED AND
COMMITTED GRAVE ABUSE OF DISCRETION AMOUNTING TO
LACK OR IN EXCESS OF JURISDICTION WHEN IT RULED THAT
DECEASED UPRESINO W. LATURNAS WAS EMPLOYED BY
PETITIONER DAITO/JEREMIE CONSTRUCTION DESIGN &
CONSULTANCY AS REGULAR EMPLOYEE WITH THE POSITION
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JAIME S. DAITO PETITION FOR CERTIORARI
OF MASON CONTINUOUSLY DURING PERIOD COVERING YEAR
2009 UNTIL UPRESINO’S UNTIMELY DEMISED ON 22 JUNE 2016.

II.

WHETHER OR NOT PUBLIC RESPONDENT NATIONAL LABOR

RELATIONS COMMISSION SERIOUSLY ERRED AND
COMMITTED GRAVE ABUSE OF DISCRETION AMOUNTING TO
LACK OR IN EXCESS OF JURISDICTION WHEN IT RULED THAT
PRIVATE RESPONDENT DOMINGA LATURNAS, WIDOW OF
DECEASED UPRESINO W. LATURNAS, IS ENTITLED TO HER
MONETARY CLAIMS COVERING THE “UNPRESCRIBED PERIOD
OF ENTITLEMENT” FROM JUNE 6, 2013 UP TO JUNE 6, 2016.

III.

WHETHER OR NOT PETITIONER DAITO/JEREMIE

CONSTRUCTION IS ENTITLED TO A TEMPORARY
RESTRAINING ORDER AND/OR WRIT OF PRELIMINARY
INJUNCTION TO ENJOIN IMPLEMENTATION OF PUBLIC
RESPONDENT NATIONAL LABOR RELATIONS COMMISSION’S
TWIN ASSAILED RESOLUTIONS PROMULGATED ON 29
SEPTEMBER 2017 AND 29 NOVEMBER 2017.

ARGUMENTS AND DISCUSSIONS

I.

WITH ALL DUE RESPECT, PETITIONER DAITO

HUMBLY SUBMITS THAT PUBLIC RESPONDENT
NLRC SERIOUSLY ERRED AND COMMITTED
GRAVE ABUSE OF DISCRETION AMOUNTING TO
LACK OR IN EXCESS OF JURISDICTION WHEN IT
RULED THAT DECEASED UPRESINO WAS
EMPLOYED BY PETITIONER DAITO/JEREMIE
CONSTRUCTION DESIGN & CONSULTANCY AS
REGULAR EMPLOYEE WITH THE POSITION OF
MASON CONTINUOUSLY DURING PERIOD
COVERING YEAR 2009 UNTIL UPRESINO’S
UNTIMELY DEMISED ON 22 JUNE 2016.

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JAIME S. DAITO PETITION FOR CERTIORARI
 PRIVATE RESPONDENT LATURNAS
FAILED TO SUBSTANTIATE
ALLEGATION OF SEVEN YEARS
CONTINUED REGULAR EMPLOYMENT

14] It is best to stress at the outset that Private Respondent

Laturnas, in filing a complaint before the Labor Arbitration Branch for
money claims based on the premise that her husband, Deceased
Upresino, was an employee of Jeremie Construction (sole
proprietorship business owned by Petitioner Daito), it is incumbent
upon her to prove that Deceased Upresino was employed by
Petitioner Daito/Jeremie Construction on a continuous basis
commencing on the year 2009 or even before Ronaldo Fuentes
(contractor of Petitioner Daito) hired his services as mason on or at
about April 2015 by the quantum of proof necessary which is
substantial evidence.

15] Needless to say, it is an oft-repeated rule that in labor

cases, as in other administrative and quasi-judicial proceedings, the
quantum of proof necessary is substantial evidence, or such amount
of relevant evidence which a reasonable mind might accept as
adequate to justify a conclusion. The burden of proof rests upon the
party who asserts the affirmative of an issue. (Valencia vs. Classique
Vinyl [G.R. No. 206390, 30 January 2017])

16] It is noteworthy that in the case of Tenazas, et. al. vs. R.

Villegas Taxi Transport (G.R. No. 192998, 2 April 2014) is found a
list of competent and relevant evidence to prove employment
relationship, none of which Private Respondent Laturnas was able to
proffer before the Labor Arbitration Branch and the NLRC. Pertinent
portion of the decision reads as follows:

“There is no hard and fast rule designed to establish the

aforesaid elements. Any competent and relevant evidence to
prove the relationship may be admitted. Identification cards,
cash vouchers, social security registration, appointment
letters or employment contracts, payrolls, organization
charts, and personnel lists, serve as evidence of employee
status x x x x He could have also presented testimonial
evidence showing the respondents’ exercise of control over
the means and methods by which he undertakes his work.”

17] In her Position Paper (Annex “C”), Private Respondent

Laturnas alleged the following:

17.1] Page no. 2 of Position Paper

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JAIME S. DAITO PETITION FOR CERTIORARI
 STATEMENT OF FACTS

Upresino was first employed with Jeremie as a mason

last 2009.

His salary history was as follows:

PERIOD DAILY WAGE RATE

2009 - 2010 Php250.00
2011 - 2016 Php300.00

17.2] Page no. 3 of Position Paper

To be allowed entry to any Jeremie’s project, its workers

were issued tshirts.

PERIOD SHIRT COLOR

2011 - 2012 Yellow
2013 Violet
2014-2016 Green

17.3] Page no. 6 of Position Paper

Deceased Upresino had been working as a mason for

Jeremie since 2009.

Upresino’s work as a mason was necessary and

desirable in Jeremie’s business given that it is into the
construction business.

Therefore, he was a regular employee enjoying security

of tenure.

18] Proceeding from the foregoing allegations, Private

Respondent Laturnas verified the truthfulness thereof affirming that
the afore-stated allegations are supported by authentic records as
shown in her Position Paper (Annex “C”). To quote:

VERIFICATION and
CERTIFICATION AGAINST FORUM SHOPPING
xxxx

3. That I have read and understood the allegations therein and

the same are true and correct of my knowledge and based
on authentic records. (underscoring and increased font
size supplied)

19] Notwithstanding the afore-quoted portion of her

Verification, NONE of the pleadings filed with the Labor Arbitration
Branch and the NLRC by Private Respondent Laturnas is supported

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JAIME S. DAITO PETITION FOR CERTIORARI
by any single piece of document that could substantiate her
allegations, affirmed under oath, that Deceased Upresino:

19.1] was continuously employed for seven (7) years as

mason by Petitioner Daito/Jeremie Construction despite
the jurisprudentially acknowledged off-and-on nature of
work in the construction industry; and

19.2] was already employed by Petitioner Daito/Jeremie

Construction on a continuous basis beginning the year
2009 or even before Ronaldo Fuentes (job contractor of
Petitioner Daito) hired his services as mason on or at
about April 2015.

20] At this point, let it be stated that a mere allegation in the

position paper is not tantamount to evidence (Tenazas vs. R.
Villegas Taxi [G.R. No. 192998, 2 April 2014]). As an allegation is
not evidence, it is elementary that a party alleging a critical fact must
support his allegation with substantial evidence (Tri-C vs. Matuto
[G.R. No. 194686, 23 September 2015]). In this regard, Private
Respondent Laturnas miserably failed as disclosed in the records of
this case.

21] On another note, it is undeniable that the afore-stated

allegations (i.e. 19.1 and 19.2) are inconsistent with the statements
that Private Respondent Laturnas affirmed under oath in her
Verification, which from legal standpoint, is intended to secure an
assurance that the allegations of a pleading are true and correct; are
not speculative or merely imagined; and have been made in good
faith. (Spouses Valmonte vs. Alcala [G.R. No. 168667, 23 July
2008])

22] By the same token, it is noteworthy that the aforesaid

allegations (i.e. 19.1 and 19.2) of Private Respondent Laturnas,
which in truth and in fact are devoid of evidentiary support but
nonetheless she affirmed under oath as being substantiated by
authentic records, are crystal clear falsehood of material matters in
her complaint against Petitioner Daito/Jeremie Construction willfully
and deliberately asserted to misled. Material matters in the sense
that these are the main facts which were the subject of the inquiry in
the Labor Arbitration Branch and at the NLRC.

23] At this point, let it be stated that the definition of the term
“material matter” in prosecution for perjury is well-settled in our
jurisprudence. In a long line of cases which dates back in the case of

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JAIME S. DAITO PETITION FOR CERTIORARI
United States vs. Pastraña (G.R. No. 5751, 6 September 1910), the
term “material matter” has consistently been defined by the
Supreme Court as -

23.1] the main fact which was the subject of the inquiry,
OR

23.2) any circumstance which tends to prove that fact, OR

23.3) any fact, or circumstance –

24.3.1) which tends to corroborate or strengthen the

testimony relative to such inquiry, OR

24.3.2) which legitimately affects the credit of any

witness who testifies.

24] All told, short of the required quantum of proof, Labor

Arbiter Almeyda and the NLRC seriously erred when it ruled that
Deceased Upresino was continuously employed for seven (7) years
as mason by Jeremie Construction and the monetary awards, which
necessarily follow such ruling, lacked factual and legal basis.

RULING OF LABOR ARBITER ALMEYDA

HAS NO BASIS IN LAW, IN JURISPRUDENCE,
OR EVEN IN FACT

25] The disquisition of Labor Arbiter Almeyda in his 12 May

2017 Decision lay bare that he took as gospel truth the bare
assertions of Private Respondent Laturnas that Deceased Upresino
was continuously employed by Petitioner Daito/Jeremie Construction
for seven (7) years as mason and the correlative entitlement of
Private Respondent Laturnas to her money claims covering the
“unprescribed period of entitlement” from June 6, 2013 up to June 6,
2016.

26] Worse, in order that Labor Arbiter Almeyda’s conclusion of

Deceased Upresino’s continued employment and correlative
entitlement of Private Respondent Laturnas to her money claims
against Petitioner Daito/Jeremie Construction will have legs to stand
on, Labor Arbiter Almeyda thrust aside the sworn statement of
Ronaldo Fuentes (Please refer to Annex “A” of Rejoinder to
Complainant’s Reply filed with the Labor Arbitration Branch.
Rejoinder to Complainant’s Reply is attached hereto as Annex “G”).

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JAIME S. DAITO PETITION FOR CERTIORARI
 27] Thereafter, wittingly or not, stated in his Decision (Annex
“H”) that Petitioner Daito/Jeremie Construction refused to disclose
the name of the contractor who hired the services of Deceased
Upresino. Pertinent portion of Labor Arbiter Almeyda’s Decision
(Annex “H” page no. 6 last paragraph) promulgated on 12 May
2017 reads as follows:

“x x x x In fact, the respondents even refused to

identify the name of their contractor. Easily therefore,
respondents Jeremie Construction and Daito were engaged in
labor-only contracting and as such, they cannot evade liabilities
arising from the worker illegally supplied by their unidentified
contractor.” (underscoring supplied)

28] It bears stressing that the aforesaid conclusion of alleged

failure to disclose has no basis in fact and in evidence. The truth of
the matter is that Petitioner Daito/Jeremie Construction disclosed in
the aforesaid Rejoinder the name of the contractor as “Ronaldo
Fuentes” and that Deceased Upresino was hired by Ronaldo
Fuentes on or at about April 2015.

29] The pertinent portion of Ronaldo Fuentes’ un-refuted

Sinumpaang Salaysay, which substantially established the fact of
Deceased Upresino’s period of limited employment from April 2015
up to June 6, 2016 only, contrary to Private Respondent Laturnas’
bare and self-serving allegation of seven (7) years continuous
employment in Jeremie Construction, reads as follows:
xxxx

“3. Na noong Abril 2015, nakakuha ako ng trabaho sa

Jeremie Construction Design and Consultancy na gumawa ng
isang (1) bahay na muna sa Beverly Homes na nasa Loma De
Gato, Marilao, Bulacan.”

xxxx
“8. Na matapos na magsimula na magtrabaho sa akin
si Upresino W. Laturnas noong humigit kumulang Abril 2015
hindi nagtagal siya ay naaksidente noong ika-6 ng Hunyo
2016.”

30] Certainly, it is startling to a reasonable mind since there is

not even a hint of a rationalization why Labor Arbiter Almeyda opted
to state in his Decision (Annex “H”) that Petitioner Daito refused to
disclose the name of the contractor who hired the services of
Deceased Upresino. Notwithstanding the fact that it is undeniable he
pored over the Sinumpaang Salaysay of Ronaldo Fuentes as
evidenced by the last sentence (page 2) of his Decision (Annex “H”)
which reads as follows:

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JAIME S. DAITO PETITION FOR CERTIORARI
 “To prove their claim, they submitted the affidavit of Ronaldo
Fuentes attesting the fact that Upresino was single. (Annex A of
the Respondents’ Rejoinder)”

With all due respect, this was at best a selective appreciation of

portion of the entire evidence which is offensive to reason.

31] In this regard, it is highly relevant to state that the right of

Petitioner Daito/Jeremie Construction to adduce evidence, without
the corresponding duty on the part of the Labor Arbitration Branch to
consider it, is vain. Such right is conspicuously futile if the Labor
Arbitration Branch to whom the evidence was presented thrust it
aside without consideration. Such is an arbitrary act, an abuse of
discretion, and wholly without authority. Highly instructive at this
point is the pronouncement of the Supreme court in Edwards vs.
McCoy (G.R. No. L-7474, 25 March 1912), to wit:

“What is a hearing within the meaning of the law?

Generally speaking, it may be said to be an opportunity given
to the alien to present his case; to adduce his evidence tending
to establish the rights which he asserts. But, in reality, it is
something more. He is not only entitled to present his evidence
but he is also entitled to have it considered. The object of a
hearing is as much to have evidence considered as it is to
present it. The right to adduce evidence, without the
corresponding duty on the part of the board to consider it, is
vain. Such right is conspicuously futile if the person or persons
to whom the evidence is presented it can thrust it aside
without notice or consideration.

xxxx

If a board, stating the facts upon which it proposes to

rest its decision, draws a conclusion from those facts legally
impossible from any point of view, the drawing of such a
conclusion is an arbitrary act, an abuse of discretion, and
wholly without authority. This means, really and in substance,
that there was no hearing. Under such circumstances this court
has jurisdiction to review.”

32] Notably, it is barefaced that there is not a shred of positive

and credible evidence that supports the factual finding of Labor
Arbiter Almeyda that:

32.1] Deceased Upresino, commencing on the year 2009

up to June 2016, continuously worked as a regular
employee (mason) of Petitioner Daito/Jeremie
Construction; or

32.2] Deceased Upresino was already employed by

Petitioner Daito/Jeremie Construction on a continuous
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JAIME S. DAITO PETITION FOR CERTIORARI
 basis commencing on the year 2009 as a regular employee
(mason) or even before Ronaldo Fuentes (contractor of
Petitioner Daito/Jeremie Construction) hired his services as
mason on or at about April 2015.

33] Thus, purely conjecture and speculation on the part of

Labor Arbiter Almeyda and have not been established by sufficiently
convincing evidence or any degree of certitude. Lamentably, far too
much was concluded, inferred, or deduced by Labor Arbiter Almeyda
from the baseless and untruthful assertions of Private Respondent
Laturnas.

34] Prescinding from the above, the ramification is that the

correlative entitlement of Private Respondent Laturnas to her money
claims covering the “unprescribed period of entitlement” utilizing the
reckoning point of June 6, 2013 has no basis in fact and in evidence.

RULING OF THE NLRC (2ND DIVISION)

HAS NO BASIS IN LAW, IN JURISPRUDENCE,
OR EVEN IN FACT

35] A perusal of the 29 September 2017 Resolution of the

NLRC (Annex “A”) shows, doubtlessly, that the NLRC seems to
have uncritically taken the disquisition of Labor Arbiter Almeyda at
face value and adopted his position hook, line, and sinker.

36] It is also self-evident that the NLRC relied heavily on the

naked and self-serving assertions of Private Respondent Laturnas
propounded in her pleadings which have no probative weight and
unworthy of credence. Pertinent portion of the 29 September 2017
Resolution of the NLRC (Annex “A” page 4, last paragraph of
Resolution) reads as follows:

“The appeal is unmeritorious.

Complainant (Private Respondent Laturnas) indicated

in her complaint that Upresino was employed by Jeremie
Construction/Daito in 2009. He worked as a construction
worker, a job usually necessary and desirable in the business
of the respondents (Petitioner Daito and Jeremie Construction).
Thus, he had already attained regular status. He is a regular
employee of the respondent company.”

37] In the matter of Ronaldo Fuentes’ Sinumpaang Salaysay,

which as earlier discussed was arbitrarily shunted aside by Labor
Arbiter Almeyda, the NLRC clearly stated in its assailed Resolution

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JAIME S. DAITO PETITION FOR CERTIORARI
of 29 September 2017 (Annex “A” page 6, first paragraph) the
critical fact that Deceased Upresino was only hired by Petitioner
Daito’s contractor on or at about April 2015, to wit:

“In his Sworn Statement, Fuentes admitted that “Noon

Abril 2015, nakakuha ako ng trabaho sa Jeremie Construction
Design and Consultancy; xxx, Na isa sa aking trabahador sa
aking nakuhang kontrata sa paggawa ng bahay sa Beverly
Homes ay si Upresino W. Laturnas xxx” (Annex “A”,
Respondents’ Rejoinder, p.81, Records).”

38] In this light, and with all due respect, there is marked
ambivalence in this part of the disquisition of the NLRC for there is
no rationale adduce as to how the conclusion was arrived at that
Deceased Upresino was employed by Jeremie Construction for
seven (7) continuous years as mason. Whereas, the only extant
documentary evidence of Deceased Upresino’s employment is the
un-refuted sworn statement of Ronaldo Fuentes (contractor of
Petitioner Daito).

39] Suffice it to say that it is fundamentally wrong and there is

no legal or jurisprudential principle upon which it can be sustained
that simply because Ronaldo Fuentes (contractor of Petitioner
Daito/Jeremie Construction) hired the services of Deceased
Upresino as a mason on or at about April 2015, the bare and self-
serving allegations of Private Respondent Laturnas that Deceased
Upresino was employed by Jeremie Construction way back in 2009
is deemed, ipso facto, substantial evidence of Deceased Upresino’s
continuing regular employment as mason in Jeremie Construction
from the year 2009 until his untimely demised on June 22, 2016.

40] In the same breathe, both Labor Arbiter Almeyda and the
NLRC had erroneously stretched the interpretation of Department
Order No. 18-02 Series of 2002 (Rules Implementing Articles 106 to
109 of the Labor Code, as amended) to an unjustifiable and
inequitable point that simply because:

40.1] Petitioner Daito is unable to present evidence that

Ronaldo Fuentes is a legitimate contractor who hired the
services of Deceased Upresino on or at about April 2015;
and

40.2] Petitioner Daito alleged that he does not directly

employ workers in undertaking the economic business
activities of Jeremie Construction. Instead, it contracted
subcontractors (with their own hired workforce) under the
pakyaw system,

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JAIME S. DAITO PETITION FOR CERTIORARI
the bare and self-serving allegations of Private Respondent Laturnas
that Deceased Upresino was employed by Jeremie Construction way
back in 2009 is deemed, ipso facto, substantial evidence of
Deceased Upresino’s continuing regular employment as mason in
Jeremie Construction commencing on the year 2009 until his
untimely demised on June 22, 2016.

41] In the same token, the interpretation espoused both by

Labor Arbiter Almeyda and the NLRC inordinately exposed Petitioner
Daito to pecuniary liability way beyond what is provided for under
Article 106 (2nd paragraph) of the Labor Code, as amended which
reads as follows:

ARTICLE 106. Contractor or Subcontractor.

xxxx

In the event that the contractor or subcontractor fails to

pay the wages of his employees in accordance with this Code,
the employer shall be jointly and severally liable with his
contractor or subcontractor to such employees to the extent
of the work performed under the contract, in the same
manner and extent that he is liable to employees directly
employed by him. (underscoring and font size increased
supplied)

42] Simply stated, the phrase “to the extent of the work
performed under the contract” of Article 106 should have been
construed both by Labor Arbiter Almeyda and the NLRC (but failed to
accurately or even deliberately refused to accurately construe) as
the contract between Ronaldo Fuentes and Deceased Upresino
covering the period April 2015 up to June 2016 only. The reason is
because the only extant documentary evidence of Deceased
Upresino’s employment is the un-refuted Sinumpaang Salaysay of
Ronaldo Fuentes. (Please refer to Annex “A” of Rejoinder to
Complainant’s Reply filed with the Labor Arbitration Branch.
Rejoinder to Complainant’s Reply is attached hereto as Annex “G”)

43] It must likewise be stressed that even jurisprudence

recognized the off-and-on nature of work in the construction industry.
A jurisprudential fact that both Labor Arbiter Almeyda and the NLRC
turned a blind eye leading to their patent erroneous conclusion that
Deceased Upresino was employed by Petitioner Daito/Jeremie
Construction for seven (7) continuous years as a regular employee
even though substantial evidence does not obtain in the present
case.

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 44] The following pronouncements of the Supreme Court
anent off-and-on nature of work in the construction industry prove
most instructive:

44.1] Dionisio Dacles vs. Millenium Erectors (G.R. No.

209822, 08 July 2015) The pertinent portion of this
decision reads as follows:

“x x x x construction firms cannot guarantee work and funding for its

payrolls beyond the life of each project as they have no control over
the decisions and resources of project proponents or owners.”

44.2] E. Ganzon, Inc. vs. Ando (G.R. No. 214183, 20

February 2017) The pertinent portion of this decision
reads as follows:
xxxx

“As a corporation engaged in construction and residential

projects, EGI depends for its business on the contracts it is able to
obtain. Since work depends on the availability of such contracts,
necessarily the duration of the employment of its work force is not
permanent but coterminous with the projects to which they are
assigned and from whose payrolls they are paid.

xxxx

It is widely known that in the construction industry, a project

employee's work depends on the availability of projects, necessarily
the duration of his employment. It is not permanent but coterminous
with the work to which he is assigned. It would be extremely
burdensome for the employer, who depends on the availability of
projects, to carry him as a permanent employee and pay him wages
even if there are no projects for him to work on. The rationale behind
this is that once the project is completed it would be unjust to require
the employer to maintain these employees in their payroll. To do so
would make the employee a privileged retainer who collects payment
from his employer for work not done. This is extremely unfair to the
employers and amounts to labor coddling at the expense of
management.”

45] Viewed in the light of the foregoing considerations, it is

undeniably established that in arriving at its conclusion, the NLRC
seems to have turned a blind eye to facts which are of record,
overlooked vital circumstances obtaining in the present case and
patently misapplied the law and settled jurisprudence. These are
explicit manifestations that the NLRC has oversteps the limits of its
discretion to the point of being grossly unreasonable thereby acted
outside the contemplation of the law.

46] Jurisprudential principles enunciated by the Supreme

Court have taught us that:

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JAIME S. DAITO PETITION FOR CERTIORARI
 46.1] Grave abuse of discretion arises when a lower court
or tribunal violates the Constitution or grossly disregards
the law or existing jurisprudence. (Heirs of the Late
Faustina Borres vs. Abela [G.R. No. 131023 , 17 July
2007], Republic vs. Caguioa [G.R. No. 174385, 20
February 2013], Marcos vs. Heirs of the Late Dr. Andres
Navarro, Jr. [G.R. No. 198240, 3 July 2013])

46.2] In labor disputes, grave abuse of discretion may be

ascribed to the NLRC when its findings and conclusions
reached are not supported by substantial evidence or are
in total disregard of evidence material to or even decisive
of the controversy ((E. Ganzon, Inc. vs. Ando, Jr. [G.R. No.
214183, 20 February 2017]).

47] Proceeding from such premise (paragraph no. 45) and

guided by jurisprudential parameters setforth in paragraph no. 46, it
is very apparent that the NLRC, with all due respect, seriously erred
and committed grave abuse of discretion, amounting to lack or in
excess of jurisdiction, when it ruled that Deceased Upresino was
employed by Jeremie Construction as regular employee with the
position of mason continuously during period covering year 2009 until
Upresino’s untimely demised on 22 June 2016 despite dearth of
substantial evidence or are in total disregard of evidence material to
or decisive of the present controversy.

II.
WITH ALL DUE RESPECT, PETITIONER DAITO
HUMBLY SUBMITS THAT PUBLIC RESPONDENT
NLRC SERIOUSLY ERRED AND COMMITTED
GRAVE ABUSE OF DISCRETION AMOUNTING TO
LACK OR IN EXCESS OF JURISDICTION WHEN IT
RULED THAT PRIVATE RESPONDENT
LATURNAS, WIDOW OF DECEASED UPRESINO,
IS ENTITLED TO HER MONETARY CLAIMS
COVERING THE “UNPRESCRIBED PERIOD OF
ENTILEMENT” FROM JUNE 6, 2013 UP TO JUNE 6,
2016.

Petitioner Daito repleads, by way of reference, the foregoing

allegations and further states.

48] After the all-sweeping and categorical pronouncement that

employer-employee relationship existed between Deceased Upresino

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and Petitioner Daito/Jeremie Construction, the latter, failing to present
convincing evidence that Ronaldo Fuentes is a legitimate job
contractor, which finding was further echoed by the NLRC, Labor
Arbiter Almeyda ruled that Private Respondent Laturnas is entitled to
recover wage differentials, service incentive leave pay and 13th Month
Pay covering the “unprescribed period of entitlement” from June 6,
2013 up to June 6, 2016.

49] With all due respect, this postulation is incorrect and

entirely bereft of substantiation. Worse, it will render Private
Respondent Laturnas unjustly enriched at the expense of Petitioner
Daito/Jeremie Construction.

50] The reason is because nowhere in the 12 May 2017

Decision (Annex “H”) of Labor Arbiter Almeyda and 29 September
2017 Resolution (Annex A”) of NLRC could be found the
ratiocination how the “unprescribed period of entitlement” covering
June 6, 2013 up to June 6, 2016 was arrived at or from where it was
derived from. When the only extant documentary evidence of
Deceased Upresino’s employment is the un-refuted sworn statement
of Ronaldo Fuentes (contractor of Petitioner Daito) that he hired the
services of Deceased Upresino as mason on or at about April 2015.

51] Elsewise stated, the span of time that covers the

“unprescribed period of entitlement” and from where the computation
of the monetary award granted to Private Respondent Laturnas was
based is not supported by substantial evidence. This requirement of
substantial evidence is clearly expressed in Section 5, Rule 133 of
the Rules of Court which provides that "[i]n cases filed before
administrative or quasi-judicial bodies, a fact may be deemed established if it
is supported by substantial evidence, or that amount of relevant evidence
which a reasonable mind might accept as adequate to justify a conclusion."

52] Telling is the fact that both Labor Arbiter Almeyda and the
NLRC seems to have utterly ignored vital circumstances which make
their conclusion or finding pertaining the “unprescribed period of
entitlement” covering June 6, 2013 up to June 6, 2016” not in accord
with the facts and circumstances obtaining in the present case as
well as legal and jurisprudential principles.

53] Indisputedly, Labor Arbiter Almeyda and the NLRC solely

based their conclusion or finding from the naked and self-serving
assertions of Private Respondent Laturnas. Even then, these
assertions merely speak of periods of time covered by no more than
years without any specifics on calendar months of the year having

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JAIME S. DAITO PETITION FOR CERTIORARI
been provided by Private Respondent Laturnas herself.

54] In this regard, it is relevant to restate that a mere allegation

in the position paper is not tantamount to evidence (Tenazas vs. R.
Villegas Taxi [G.R. No. 192998, 2 April 2014]). As an allegation is not
evidence, it is elementary that a party alleging a critical fact must
support his allegation with substantial evidence (Tri-C vs. Matuto
[G.R. No. 194686, 23 September 2015]).

55] In brief, despite the absence of substantial evidence as to

accuracy of the “unprescribed period of entitlement” covering June 6,
2013 up to June 6, 2016”, the NLRC nevertheless assumed that such
unprescribed period of entitlement ruled by Hon, LA Almeyda was
accurate. It then went to sustain the 12 May 2017 Decision of Labor
Arbiter Almeyda.

56] Tested against the foregoing considerations as well as

jurisprudential principles discussed in paragraph no. 46, the Public
Respondent NLRC, with all due respect, seriously erred and
committed grave abuse of discretion, amounting to lack or in excess
of jurisdiction, when it ruled that the computation of the monetary
award of Private Respondent Laturnas, widow of deceased Upresino,
should be reckoned from June 6, 2013 when Petitioner Daito/Jeremie
Construction had established by substantial evidence that Deceased
Upresino was only employed by Ronaldo Fuentes (subcontractor of
Petitioner Daito/Jeremie Construction) beginning April 2015 only.

III.
ARGUMENTS IN SUPPORT OF
APPLICATION FOR ISSUANCE OF
TEMPORARY RESTRAINING ORDER AND/OR
WRIT OF PRELIMINARY INJUNCTION

Petitioner Daito/Jeremie Construction repleads, by the way of

reference, the foregoing allegations and further states:

57] Section 7 of Rule 65 of the Rules of Court provides as

follows:

SEC. 7. Expediting Proceedings; Injunctive Relief.

The court in which the petition is filed may issue orders expediting
the proceedings, and it may also grant a temporary restraining

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JAIME S. DAITO PETITION FOR CERTIORARI
 order or a writ of preliminary injunction for the preservation of the
rights of the parties pending such proceedings. The petition shall
not interrupt the course of the principal case, unless a temporary
restraining order or a writ of preliminary injunction has been
issued, enjoining the public respondent from further proceeding
with the case.

58] The obvious ramification of Rule 65, Section 7 is that while

Petitioner Daito/Jeremie Construction filed this Petition for Certiorari
with the Honorable Court, still its filing per se is insignificant for the
purpose of enjoining the Labor Arbitration Branch in the issuance of a
writ of execution.

59] Confronted with a scenario whereby the 10-day period

from the date the parties in this case received the assailed
Resolution (Annex “B”) of the NLRC promulgated on 29 November
2017 had already lapsed, it is most logical to conclude that Private
Respondent Laturnas will move for the execution of the award of the
NLRC.

60] Looking at the present instance, Petitioner Daito/Jeremie

Construction deemed it most prudent to seek solace in Section 3 of
Rule 58 of the Rules of Court which provides the grounds justifying
the issuance of a preliminary injunction, to wit:

SEC. 3. Grounds for issuance of preliminary injunction. - A

preliminary injunction may be granted when it is established:

(a) That the applicant is entitled to the relief demanded, and the
whole or part of such relief consists in restraining the commission
or continuance of the act or acts complained of, or in requiring the
performance of an act or acts, either for a limited period or
perpetually;

(b) That the commission, continuance or non-performance of the

act or acts complained of during the litigation would probably work
injustice to the applicant; or

(c) That a party, court, agency or a person is doing, threatening or

is attempting to do, or is procuring or suffering to be done, some
act or acts probably in violation of the rights of the applicant
respecting the subject of the action or proceeding, and tending to
render the judgment ineffectual.

61] What is more, the purpose of a preliminary injunction is to

prevent threatened or continuous irremediable injury to some of the
parties before its claims can be thoroughly studied and adjudicated
(Light Rail Transit Authority vs. Court of Appeals (G.R. Nos. 139275-
76 and 140949, 25 November 2004).

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JAIME S. DAITO PETITION FOR CERTIORARI
 62] It is crucial to note that if ever the execution of the assailed
twin Resolutions (Annex “A” and Annex “B”) of the NLRC (void as
these were rendered with grave abuse of discretion, amounting to lack
or in excess of jurisdiction) will not be stayed, the logical
consequence would be a classic case of taking property from
Petitioner Daito/Jeremie Construction and giving it to Private
Respondent Laturnas.

63] This would be mockery of justice. An unlawful invasion of

property rights proscribed under Section 1, Article III of our
Constitution. Section 1, Article III of the Constitution guarantees:

“No person shall be deprived of life, liberty, or property without due

process of law nor shall any person be denied the equal protection
of the law.”

64] As set forth in Gomez vs. Concepcion (G.R. No. L-23921,

30 March 1925) in which case the Supreme Court articulated the
effects of void judgment, as follows:

"A void judgment is in legal effect no judgment. By it no rights are

divested. From it no rights can be obtained. Being worthless in
itself, all proceedings founded upon it are equally worthless. It
neither binds nor bars any one. All acts performed under it and all
claims flowing out of it are void. The parties attempting to enforce
it may be responsible as trespassers.”

65] Furthermore, not to be ignored is the hard and indelible

truth that the assailed twin Resolutions (Annex “A” and Annex “B”)
of the NLRC are unsupported by any iota of sufficiently convincing
evidence. This scenario, with all due respect, lead us to cast doubt
that the twin Resolutions (Annex “A” and Annex “B”) of the NLRC
are based on rational and logical assessment of the facts and
circumstances obtaining in this case. Instead, these are pure
reactions to feelings engendered by human frailties of pity and
predilections.

66] With all due respect, it is not amiss to conclude, given the
factual backdrop of this case, that both Labor Arbiter Almeyda and the
NLRC may have played the role of "knights in shining armor" coming
to the aid of Private Respondent Laturnas, who in her position paper:

66.1] portrayed herself as the oppressed grieving widow of

Deceased Laturnas. And unfairly denounced, Petitioner
Daito as the unrighteous employer of her deceased
husband - Upresino; and

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JAIME S. DAITO PETITION FOR CERTIORARI
 66.2] portrayed herself as the miserable, pitiful, and
unlettered widow of Deceased Upresino. Upon the other
hand, Petitioner Daito as insincere and manipulative. She
unfairly and without basis in fact and in evidence accused
Petitioner Daito of misleading her that she will be provided
with means of livelihood now that Upresino has eternally
closed his eyes.

67] Viewed in the light of the foregoing considerations, worth

iterating is the case of Mateo Jr. vs. Villaluz (G.R. Nos. L-34756-59,
31 March 1973) where the Supreme Court made a discourse about
the topic “cold neutrality of an impartial judge.” To quote:

“It is now beyond dispute that due process cannot be satisfied in

the absence of that degree of objectivity on the part of a judge
sufficient to reassure litigants of his being fair and being just.

x x x x

In the language of Justice Dizon: "It has been said, in fact, that
due process of law requires a hearing before an impartial and
disinterested tribunal, and that every litigant is entitled to
nothing less than the cold neutrality of an impartial judge."
(underscoring supplied)

68] Needless to say, due process is a Constitutional guarantee.

Section 1, Article III of the Constitution states as follows:

“No person shall be deprived of life, liberty, or property without due

process of law nor shall any person be denied the equal protection
of the law.”

69] It does not stretch one's imagination to see that deprivation

of Constitutional and statutory rights are kinds of injury whereby the
concomitant damage resulting therefrom cannot be measured by any
certain pecuniary standard and in that sense the threatened injury is
irreparable. Thus, falls within the doctrine laid down by the Supreme
Court in the landmark case of Social Security Commission vs.
Bayona (G.R. No. L-13555, 30 May 1962), to wit:

"An irreparable injury which a court of equity will enjoin

includes that degree of wrong of a repeated and continuing
kind which produce hurt, inconvenience, or damage that can
be estimated only by conjecture, and not by any accurate
standard of measurement (Phipps v. Rogue River Valley Canal
Co., 7 ALR, 741).”

70] That being said, justice and equity demand that the parties
in this controversy be maintained in their status quo so that no

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JAIME S. DAITO PETITION FOR CERTIORARI
advantage may be given to one to the prejudice of the other.

71] Tested in the light of all the afore-stated statutory and

Constitutional provisions as well as jurisprudential principles,
Petitioner Daito/Jeremie Construction humbly submits that it is
entitled to injunctive relief and preservative remedies for the
protection of its substantive rights and interests as well as forestall
a scenario whereby any action which may be taken by the Honorable
Court in the above entitled case may be rendered ineffective or may
become moot and academic, and that Petitioner Daito/Jeremie
Construction would stand to suffer grave and irreparable injury.

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed of this Honorable Court:

1] That this Petition for Certiorari be given due course;

2] Pending resolution of this case, and upon such bond as the

Honorable Court may equitably and reasonably fix, a Temporary
Restraining Order be issued to enjoin Public Respondent NLRC or
any tribunal, officer, or person acting under its authority from issuing
a Writ of Execution in the case docketed as NLRC LAC NO. 09-
002910-17(4)/NLRC CN RAB-III-08-2441-16 entitled “Dominga
Laturnas for and in Behalf of Her Deceased Husband Upresino
Laturnas (Complainant) vs. Beberly Homes, Jeremie Construction
Design and Consultancy and its Owner Jaime S. Daito
(Respondents);”

3] After proper proceedings, a Writ of Preliminary Injunction be

issued to restrain Public Respondent NLRC or any tribunal, officer, or
person acting under its authority from committing the aforesaid act
under the preceding paragraph; and

4] After proper proceedings, judgment be rendered:

4.1] Making the preliminary injunction permanent with

respect to the act stated in paragraph 2 of the Prayer;

4.2] Annulling and setting aside the Resolution of Public

Respondent NLRC promulgated on 29 September 2017
and Resolution promulgated on 29 November 2017 in

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JAIME S. DAITO PETITION FOR CERTIORARI
 NLRC LAC NO. 09-002910-17(4)/NLRC CN RAB-III-08-
2441-16 for having been issued with grave abuse of
discretion amounting to lack or in excess of jurisdiction; and

4.3] a new one be entered ordering the NLRC to re-

compute the award of wage differentials, 13th month pay,
and service incentive leave pay exclusively for the period
covering April 6, 2015 up to June 6, 2016 only.

Other reliefs as may be deemed just and equitable under the

premises are likewise prayed for.

Respectfully submitted.

Bocaue, Bulacan for the City of Manila, February ____, 2018.

JAIME S. DAITO
Petitioner

Republic of the Philippines)

Municipality of Bocaue ) s.s.
Province of Bulacan

VERIFICATION and
CERTIFICATION OF NON-FORUM SHOPPING

I, Jaime S. Daito, Petitioner in the above-titled case, under

oath, deposes and says that:

1] I prepared the foregoing Petition for Certiorari;

2] I have read and understood the contents thereof;

3] The allegations therein are true and correct of my personal

knowledge and/or on the basis of copies of documents and records in
my possession;

4] I hereby certify that I have not commenced any other action

or proceeding involving the same issues in the Supreme Court, the
Court of Appeals, or any other tribunal or agency;

5] To the best of my knowledge and belief, no such action or

proceeding is pending in the Supreme Court, the Court of Appeals, or

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JAIME S. DAITO PETITION FOR CERTIORARI
any other tribunal or agency;

6] And if I should thereafter learn that a similar action or

proceeding has been filed or is pending before the Supreme Court,
the Court of Appeals, or any other tribunal or agency, I undertake to
report that fact within five (5) days therefrom to this Honorable Court;

7] I executed this verification/certification to attest to the

truth of the foregoing facts and to comply with the provisions of
Administrative Circular No. 04-94 of the Honorable Supreme Court.

IN WITNESS WHEREOF, I have hereunto affixed my

signature this ____th day February 2018 in the Municipality of
Bocaue, Province of Bulacan.

JAIME S. DAITO
Petitioner/Affiant

SUBSCRIBED AND SWORN to before me, this ______th day

of February 2018, in Bocaue, Bulacan, Affiant exhibiting to me his
Voter’s Identification No. 1411-0241A-A2866JSD10003-4 issued by
the COMELEC - Marilao, Bulacan, bearing his photograph and
signature as competent proof of identity.

AMADO S. SANDEL, JR.

Notary Public
Until December 31, 2018
PTR No. 1123128, Bocaue
Bulacan, January 3, 2018
Roll of Attorneys No. 27207

Doc. No. :
Page No. :
Book No. :
Series of 2018.

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JAIME S. DAITO PETITION FOR CERTIORARI
 WRITTEN EXPLANATION

Service of this PETITION FOR CERTIORARI to the NLRC

(2nd Division), Labor Arbiter Roderick Q. Almeyda, counsel for
Private Respondent - Atty. Trinidad V. Balmeo, and Private
Respondent Dominga Laturnas was not done personally but through
registered mail due to lack of manpower to effect personal service.

JAIME S. DAITO
Petitioner

Copy furnished:

REPUBLIC OF THE PHILIPPINES

NATIONAL LABOR RELATIONS COMMISSION (2nd Division)
PPSTA Building No. 245 Banawe Street
Quezon City, 1114 Metro Manila

HON. LABOR ARBITER RODERICK Q. ALMEYDA

Department of Labor and Employment
National Labor Relations Commission
Regional Arbitration Branch No. III
City of San Fernando, Pampanga

ATTY. TRINIDAD V. BALMEO

Public Attorney III
Public Attorneys’ Office
Unit 2-A Mary Ville Square
McArthur Highway, Saluysoy
Meycauyan City, Bulacan

DOMINGA LATURNAS
No. 26 Villa Lourdes Loma de Gato,
3019 Marilao, Bulacan

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