REPUBLIC OF THE PHILIPPINES

CITY OF _____________________) S.S.

JOINT AFFIDAVIT OF UNDERTAKING

We, ROBERTO V. PASAMBA, of legal age, Filipino, with office address at

Bertaphil Compound CSEZ, Clarkfield City, Pampanga, and NATHALIE A.
PIATOS, of legal age, Filipino, and a resident of Davao City after all being sworn
in accordance with law, depose and state:
1. That ROBERTO V. PASAMBA is the Senior Corporate Counsel of
IQOR PHILS., INC/ RMS Collect Phils., Inc while NATHALIE A.
PIATOS is a former employee of IQOR PHILS./ RMS Collect Phils., Inc;
2. That on January 18, 2016, NATHALIE A. PIATOS filed a case for illegal
suspension/ dismissal against IQOR PHILS., INC, CHRISTINE MARIE
ABUBO AND JOVELYN NAVAL. In a Decision dated December 27,
2016, the Labor Arbiter dismissed with prejudice the case filed by
Nathalie A. Piatos for lack of merit and legal basis;
3. That on April 7, 2017, Nathalie A. Piatos filed an appeal praying for the
reversal of the decision of the Labor Arbiter. On May 30, 2017, the NLRC
rendered a Decision setting aside the order of the Labor Arbiter. IQOR
PHILS./ RMS Collect Phils., Inc. filed a Motion for Reconsideration but
it was denied, thus, Petition for Certiorari under Rule 65 in the Court of
Appeals where it was docketed as CA-GR SP No. 152412;
4. That on January 31, 2018, the Court of Appeals Sixth Division dismissed
the petitioner and affirmed in toto the Decision and Resolution of the
NLRC. IQOR PHILS.,/ RMS Collect Phils., Inc. filed a Motion for
Reconsideration but the said Motion for Reconsideration was denied by
the Court of Appeals Former Sixth Division on May 28, 2018;
5. That before the denial of the Motion for Reconsideration, IQOR PHILS.,
/ RMS Collect Phils., Inc., through its Senior Corporate Counsel, Atty.
Roberto V. Pasamba, and Nathalie A. Piatos agreed to settle for the
amount of NINE HUNDRED THOUSAND PESOS (P900,000.00). The
said settlement was to be conducted in Davao City, the place of
residence of Nathalie A. Piatos;
6. That on June 6, 2018, Atty. Roberto V. Pasamba and Nathalie A. Piatos
met in NLRC Davao where the latter received the abovementioned
amount. Nathalie A. Piatos executed and signed a Release Waiver and
Quitclaim where she recognized that the amount of Nine Hundred
Thousand Pesos (P900, 000.00) as the full and complete satisfaction of
the amount due to her from IQOR PHILS.,/ RMS Collect Phils., Inc. The
said Release Waiver and Quitclaim was subscribed by Labor Arbiter
Franico C. Maskariño. A copy of the Release Waiver and Quitclaim is
attached in this Affidavit as Annex “A”;
7. That Atty. Roberto V. Pasamba has clearly explained to Nathalie Piatos
in English and Filipino that by signing the waiver and quitclaim, she is
releasing her former employer from any liability or claim that she has or
she may have from the corporation;
8. That pursuant to the waiver and quitclaim signed by Nathalie Piatos, on
June 11, 2018, IQOR PHILS.,/ RMS Collect Phils., Inc., through its
counsel, Atty. Roberto V. Pasamba filed a Motion to Dismiss in the
Court of Appeals Sixth Division where the case is pending. On July 18,
2019, this Honorable Court required the Petitioners to submit within ten
(10) days from the receipt of the resolution, a clear and legible certified
true copy of the settlement agreement between the petitioners and the
private respondent;
9. That IQOR PHILS.,/ RMS Collect Phils., Inc., sought a certified true
copy of the waiver and quitclaim signed by Nathalie Piatos from NLRC
Davao but NLRC Davao said that it cannot issue or give a certified true
copy of the waiver and quitclaim because the said document did not
originate from their office;
10. That the affiants herein confirm that a release waiver and quitclaim was
indeed signed on June 6, 2018 in Davao and that Nathalie Piatos signed
and executed the document voluntarily and had fully understood the
contents of the waiver and quitclaim and that she freely gave her
consent without any threat, violence, duress, intimidation or under
influence. As a result, Nathalie Piatos is not interested in pursuing the
case pending as CA-GR SP No. 152412 that she filed against her former
employers anymore;
 11. That we are issuing this affidavit to attest to the truth of the
abovementioned facts and for any legal purposes it may serve;

IN WITNESS WHEREOF, we have hereunto affixed our signatures this ___ day
of August 2019 at ________________, Philippines.