Affidavit-of-hr-chicosci-1.docx

R E P U B L I C O F T H E P H IL I P P I N E S ) CITY OF ILOILO ) Sc. x---------------------------------------------x

ABC Corporation,

CASE No. 1893-1902

Claimant versus

Complaint for Specific Performance and Damages

GE Philippines Inc.

Respondent x- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x AFFIDAVIT OF ANNIE BATUMBACAL I, Annie Batumbacal, 42 years old, married, and living in Avida Towers Atria 2, Don Donato Pison Avenue, Atria Park District, San Rafael, Mandurriao, Iloilo City, witness for the Respondent in this case, states under oath that:

PRELIMINARY STATEMENT The persons examining me are Atty. Justine Patricio and Atty. Jocedale Araneta with office address at Rm 303, Rada Building, General Luna Street, Iloilo City, Philippines, Iloilo City. The examination is being held at the same address. I am answering their questions voluntarily, to the best of my knowledge and fully conscious that I do so under oath and may face criminal liability for false testimony and perjury.

PURPOSE This affidavit/testimony of witness ANNIE BATUMBACAL is being offered to provide information as to the employment of MR. JEROME RAY BENNETT with Chicosci Manpower, Incorporated and his duties and responsibilities stated in his contract of employment. This Affidavit is being offered to prove the following: 1. That Mr. Jerome Ray Bennett is under the employ of Chicosci Inc. as hired by the Annie Batumbacal, being the HR Manager of Chicosci.

2.

That Mr. Jerome Ray Bennett has understood his contract with his employer, Chicosci; 3. That Mr. Jerome Ray Bennett has been properly oriented with the terms and conditions of his contract with Chicosci Inc. 4. That Mr. Jerome Ray Bennett’s affidavit as a witness in this current case is prohibited pursuant to the terms and conditions he had previously signed voluntarily and competently, as embodied in his employment contract with Chicosci Inc; 5. That Mr. Jerome Ray Bennett is one of the Healthcare Field Engineers of Chicosci recommended by the company to the GE Philippines Inc. Q. Please state your name and other personal circumstances for the record. A. I am Annie Batumbacal, 42 years old, married, and living in Avida Towers Atria 2, Don Donato Pison Avenue, Atria Park District, San Rafael, Mandurriao, Iloilo City, Philippines. Q. What is the main business of Chicosci Manpower, Inc.? A. The company is an outsourcing company that provides engineering services that best suit the needs of dynamic market environment. Many of the world's most competitive firms turn to contract engineering services to meet their needs. This is true for companies with no in-house engineering as well as companies with extensive in-house expertise. Chicosci Manpower Inc. routinely works with both. With the right provider, outsourced engineering teams can develop complete products and transition them to production, or they can develop only critical subsystems. In both cases, outsourcing a project to an engineering services firm can free management resources and bring products to market faster. In short, contract engineering services provide surge capacity and flexibility that companies require when they are developing complex systems under aggressive schedules. Q. What is your position with Chicosci Manpower, Inc.? A. I am the HR Manager of Chicosci Manpower, Inc. Q. How long have you been an HR Manager of Chicosci Manpower, Inc? A. 18 years since the company started in 1999. Q. What is your role and responsibilities as HR Manager of Chicosci Manpower, Inc? A. As an HR manager, I perform a variety of tasks, which is leading the company’s HR programs and policies and apply to employee relations, compensation, benefits, safety, performance and staffing levels. Typically, I use my recruitment and interviewing skills to identify staff vacancies and select candidates for open positions, have the hired employee sign the contract of employment and give instructions relating to their pre-employment. Also, typically skilled in promoting healthy relationships between staff and management through mediation, handling labor disputes and guiding department managers through employee issues. I also conduct employee training and orientation, administer a benefits program, analyze compensation and other competitive data and prepare budgets and other tasks as the company may deem proper.

Q. How did Chicosci Manpower, Inc. and GE Phils get involved? A. GE Phils., Inc. hired Chicosci to supply the needed manpower for certain projects. The GE Philippines usually tap the company on-call whenever they are looking for installation experts and specialists for their projects. Q. Is Mr. Jerome Ray Bennett an employee of Chicosci? A. Yes. He is one of the Healthcare Field Engineers of Chicosci Inc. Q. Were you the one who hired Mr. Jerome Ray Bennett? A. Yes. Q. Did Mr. Jerome Ray Bennett fully understood his contract of employment with Chicosci? A. Yes. It was explained to him before he signed his contract. All parts of the contract were fully accepted by Mr. Jerome Ray Bennett. Q. Is there a non-compete/non-disclosure/non-solicitation agreement stated in the employment contract that Mr. Jerome Ray Bennett signed? A. Yes. It was completely explained to him. Q. Were you notified that Mr. Jerome Ray Bennett gave his testimony in this present case, involving Chicosci? A. No. Mr. Jerome Ray Bennett did not notify me that he will be giving a statement, which involves his employer, Chicosci. Q. So there was no permission from the part of Chicosci regarding Mr. Bennett’s testimony? A. None. There was no permission at all. I don’t even have a copy of his affidavit. That I am declaring under oath that the above mentioned documents, stocks and properties are now deemed lost and beyond recovery; and That I am executing this Affidavit to attest to the truth of the foregoing statements and to support my insurance application/claim and for whatever legal purpose it may serve. IN WITNESS WHEREOF, I hereby affixed my signature hereunder this 10th day of March, 2014 in the City of Iloilo, Philippines.

ANNIE BATUMBACAL

Affiant

SUBSCRIBED AND SWORN to before me, a notary public in and for the City and Province of Iloilo, this 12th day of February, 2018, by Annie Batumbacal who has been

personally identified by me to be the very same person who executed and signed the foregoing Affidavit based on competent evidence of his identity. WITNESS MY HAND AND SEAL this 12th day of February, 2018 in the City of Iloilo, Philippines.

Doc No. _____; Page No. _____; Book No. _____; SERIES OF 2018.

Atty. Bo Sanchez Notary Public for Iloilo City 6 Jupiter St., Greenland Village, Iloilo City Appointment No. 123 Until December 31, 2018 IBP No. 123456; 01/10/18—Iloilo City PTR No. 123456; 01/10/18—Iloilo City Roll No. 1234 01/10/18 MCLE No. I 001234; 9/09/17 MCLE No. II 005678; 12/09/17 Serial No. of Commission M-12 Doc No. 12 ; Page No. 34; Book No. V; Series of 2018.

ATTESTATION The undersigned ATTY. JUSTINE PATRICIO, of legal age, single, and with law office address are Room 303, Rada Building, General Luna Street, Iloilo City, Philippines, under oath, deposes and states: 1.

She is the Legal Counsel for the respondents in the above-entitled case;

2. She faithfully recorded or caused to be recorded the questions she asked and the corresponding answers that the above-named witness gave; 3. Neither she nor any other person then present or assisting her coached the witness regarding the latter's answers; and 4. She conducted the examination of the witness at her law office located at Room 303, Rada Building, General Luna Street, Iloilo City, Philippines. IN WITNESS WHEREOF, I have hereunto set my hand on this 12th day of February at Iloilo City.

JUSTINE PATRICIO

Affiant JUSTIN PATRICIO Attorney Until December 31, 2018 PTR No. 987654 Issued on January 3, 2018 Iloilo City IBP No. 876543, 1-3-14 Atty. Roll No. 98789 SUBSCRIBED AND SWORN TO BEFORE ME, a notary public in Iloilo City on day of February 2018, Affiant personally came and appeared with Driver’s License NO. D04-00-001234 issued by the Land Transportation office on April 10, 2010, bearing her photograph and signature and Passport No. 0012346982 issued by the Department of Foreign Affairs on April 10, 2004, known to me as the same person who personally signed the foregoing instrument before me and avowed under the penalty of law to the whole truth of the contents of said instrument. 12th

Atty. Bo Sanchez Notary Public for Iloilo City 6 Jupiter St., Greenland Village, Iloilo City Appointment No. 123 Until December 31, 2018 IBP No. 123456; 01/10/18—Iloilo City PTR No. 123456; 01/10/18—Iloilo City Roll No. 1234 01/10/18 MCLE No. I 001234; 9/09/17 MCLE No. II 005678; 12/09/17 Serial No. of Commission M-12 Doc No. 12 ; Page No. 34; Book No. V; Series of 2018.

Copy furnished: Copy Furnished: (By Registered Mail) JOHN MARTI MAGHOPOY Counsel for Respondent GREYHOUNDS LAW FIRM Rm 303, Rada Building, General Luna Street, Iloilo City