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Republic of the Philippines

Department of Labor and Employment


PHILIPPINE OVERSEAS EMPLOYMENT ADMINISTRATION
ADJUDICATION OFFICE
Cebu City

JONABELLE P. ARANCO
Complainant,

VS. POEA CASE NO. DAW 18-03-0967


FOR: DISCIPLINARY ACTION AND
LEGAL SUPPORT
HARRY B. ARANCO
Respondent.
x-----------------------------/

SUPPLEMENTAL COMPLAINT

Complainant JONABELLE P. ARANCO, through the undersigned


counsel most respectfully submits this SUPPLEMENTAL COMPLAINT
and avers that:

1. Complainant JONABELLE P. ARANCO, a Filipino, of legal age,


married, and a resident of Damolog, Sogod, Cebu;

2. Respondent HARRY B. ARANCO, also a Filipino, of legal age,


married, and a resident of Bagakay, Sogod, Cebu;

3. The parties were legally married1 on 19 March 2010 at 6th


Municipal Circuit Trial Court of Catmon-Sogod-Carmen, Catmon,
Cebu;

4. Their marriage was not annulled nor was it legally


terminated. It was therefore still valid and subsisting;

5. However, last 29 November 2017, Complainant went to the


Philippine Overseas Employment Administration (POEA) where
she found that her husband, the respondent, stated in his
Overseas Filipino Worker Information2 that he is SEPARATED in
his civil status;

6. Due to this intentional false and misrepresentation of


respondent, complainant did not anymore receive any allotment
from him since October of 2017 up until now. Worst, respondent

1
The parties’ marriage certificate is already attached to the record of this case.
2
A copy is herein attached as Annex “Supplemental-A”
have not communicated with her. In fact during the last
scheduled hearing on 17 August 2018, respondent did not appear
although he was represented by her sister by virtue of a Special
Power of Attorney notarized a day prior to the schedule date or
on16 August 2018 only;

7. This act of respondent caused mental and emotional


anguish, public ridicule and humiliation to the complainant who
is a public school teacher;

8. Having a subsisting marriage and being the legal wife of


respondent, she is his legal beneficiary and is therefore entitled to
be provided with financial support by way of allotments;

9. For that respondent HARRY B. ARANCO clearly violated the


following provisions of the 2016 REVISED POEA RULES AND
REGULATIONS GOVERNING THE RECRUITMENT AND
EMPLOYMENT OF SEAFARERS:

RULE V DISCIPLINARY ACTION AGAINST SEAFARER

SECTION 128. Grounds for Disciplinary Action and their


Penalties. — Commission by a seafarer of any of the
offenses enumerated below or of similar offenses shall be
a ground for disciplinary action for which the
corresponding penalty shall be imposed:

A. PRE-EMPLOYMENT OFFENSES:

1. Submitting, furnishing or using false information or


documents or any form of misrepresentation for the
purpose of job application or employment.

xxx xxx xxx

RULE VII Code of Discipline For Filipino Seafarers

SECTION 216. Obligations of Filipino Seafarers. — It is


the duty of all seafarers to conduct themselves in the
most professional, responsible and ethical manner in the
performance of their duties and fulfill the following
obligations:

A. DUTY TO FAMILY:
1) To provide ample financial and moral support to
his/her family in the Philippines; and
2) To communicate with his/her family as often as he/she
can and make his/her presence felt just as if when he/she
is around.

10. Complainant already filed a complaint for disciplinary


action against the respondent. Thus, this supplemental
complaint for the respondent to provide financial support to
complainant in the amount that she is entitled to receive which
he clearly failed to provide since October 2017.

MANIFESTATION OF CHANGE OF ADDRESS

Moreover, the undersigned counsel most respectfully makes


record of her change of address and requests that, henceforth, the
undersigned be furnished with copies of all the orders, resolutions,
notices and other pleadings at:

Unit 35, 4/F, VCMC Shalom Center,


No. 85 Osmeña Blvd., Cebu City

PRAYER
WHEREFORE, premises considered it is most respectfully prayed
unto this Honorable Office, that judgment be rendered in favor of the
Complainant as follows:
i. For Respondent HARRY B. ARANCO be disciplined and the
corresponding proper sanction be imposed on him; and

ii. For him to provide financial support to complainant in


the amount that she is entitled to receive.

All other reliefs, just and equitable under the premises are likewise
prayed for.
Respectfully submitted this ___ August 2018 at Cebu City.

ROSELETTE ANN A. COLIS


Roll of Attorney’s No. 65193
IBP Membership No. 1084979, Cebu City Chapter, 12/05/17
PTR No.886909001, Cebu City, 1/08/18
MCLE Compliance No. VI – 0003595 10/25/17
(032) 340-9552/0933-306-1259/0906-024-6929
Unit 35, 4/F, VCMC Shalom Center, No. 85 Osmeña Blvd., Cebu City

Copy Furnished:
Harry B. Aranco
Bagakay Sogod Cebu 6007
Republic of the Philippines )
City of Cebu ) S.S.

VERIFICATION

I, JONABELLE P. ARANCO, a Filipino, of legal age, married, and a resident of Damolog,


Sogod, Cebu, after having been duly sworn to in accordance with law, hereby depose and state:

1. That I am the Complainant in the above-entitled case.

2. That I have caused the preparation and filing of this Supplemental Complaint;

3. That I have read and understood the contents thereof and the same are true and correct on
the basis of my personal knowledge;

4. That I have not commenced any other action, counterclaim or proceeding involving the
same issues in the Supreme Court, the Court of Appeals, or any other tribunal or agency
and to the best of my knowledge, no such action or proceeding is filed or pending in the
Supreme Court, in the Court of Appeals, or different divisions thereof, or any tribunal or
agency or that stated above;

5. That if I should learned that a similar action or proceeding has been filed or pending before
the Supreme Court, the Court of Appeals, or any other tribunal or agency, we undertake to
inform the court within five (5) days thereafter.

IN WITNESS WHEREOF, I have hereunto set my hand this ___ August 2018 at Cebu City,
Philippines.

JONABELLE P. ARANCO
Complainant/Affiant
DepEd Employee No. 433086

SUBSCRIBED AND SWORN TO before me this ____ August 2018 at Cebu City,
Philippines, by the herein affiant who showed to me her competent proof of identity as shown-
above.

Doc No.____
Page No.___
Book No.___
Series of 2018

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