COMPLAINT-AFFIDAVIT
I, , of legal age, American citizen, with postal address at 206, Florida,
United States, where processes and summons of this Honorable Office may
be served, after having been sworn to in accordance with law, hereby depose
and state that:
1. I am filing this instant Complaint against with postal address at
Taguig, Philippines. He may be served with orders, notices, writs, subpoena
and other processes of this Honorable Office at the foregoing address.
2. Defendant is the owner of Mabuhay Clinics with several
branches in the Philippines which offers chiropractic treatments to patients.
3. Sometime in June 2017, I was offered by Defendant employment
as a chiropractor consultant.
4. At that time, I was working in China and resigned to accept the
job opportunity offered by Defendant.
5. On July 1, 2017, I started working for him at the said clinic in
Quezon City.
6. Being in Quezon City, Defendant and I rarely interacted and had
no problems with him during the first few weeks of my employment as
chiropractic consultant.
7. Sometime in July 2017, my chiropractic assistants and I
underwent pre-employment medical check-ups. One of my said assistants
turned out to have tuberculosis but failed to inform the clinic of his
condition. The Human Resources Department also failed to follow up on the
results of our check up.
8. It was only in September of 2018 that the testing center where we
had our pre-employment medical check-up informed us that the said
chiropractor assistant has tuberculosis.