Consider the following facts. Draft the document sought for.

Plow through the facts

with methodical eyes of a legal researcher: determine the issue, and substantiate your
arguments with applicable legal provisions and jurisprudence. Do not forget your citations.
Use yellow paper.
Mr. Moe and Moes Trading are engaged in food distribution operating in Pangasinan,
maintaining at least 100 employees.
Marge was employed by Moes Trading as an account developer in schools, and to secondary
account such as public transport terminals, bus stops, restaurants and convenience stores. She had
been employed by then since January 2010 until she was forced to submit her resignation on January
2015. She was receiving a daily wage of P300.00 per day at the time of her employment.
Disco Stu and Abu were Junior and Senior Sales Agents, respectively. They were in-charge of
store-to-store selling and collection. Disco Stu had been an employee of Moes Trading since
February 2010 until his cessation from employment on March 2015 and was receiving daily wage of
P210.00 per day, below the minimum daily wage prescribed for the area.
Abu was an employee of Moes Trading since January 2009 until February 2015/ He was
receiving daily wage of P200.00 per day.
Marge, Disco Stu and Abu posted cash bonds conditioned as security for any loss or shortage
in their collections during the period of their employment. Marge posted a cash bond in the amount of
P18, 800.00, Disco Stu in the amount of P16, 700.00 and Abu in the amount of P17, 100.00.
Toward the latter part of 2014, Moe informed Marge that the business will be ceasing
operations due to business losses. She was informed by Moe that she should file her resignation by
the end of the year in order that her monetary claims can already be processed, otherwise, Moe will
no longer have any money to pay her. She was forced to file her resignation on January 2015, but up
to the present, her cash bond, 13 th month pay, and salary for December 2014 had not yet been paid
despite being promised by Moe to do so as a condition for her forced resignation.
Disco Stu and Abu, on the other hand, were informed on February 14, 2015 that it will be their
last day of employment as Moe will be closing shop due to business losses. They were informed that
they will just be called after six months if the current financial and business condition of Moes
business improves.
Moe however did not serve any written notice to its employees and to the Department
of Labor and Employment of the reason and effective date of closure of its business at least a month
before its intended cessation of operations.
However, Disco Stu and Abu learned that some of their co-employees were
immediately called to return for work on February 16, 2015 and that Moes Tradings normal operation
continued. They reported to Moes office and demanded that they return to work but the latter refused,
instructing them when the financial condition of his business improves as relayed before. Disco and
Stu and Abu then asked for the refund of their cash bond to augment their daily expenses until they
can return to work, but Moe merely promised them that he would look into it.
After waiting for what appears like eternity, Marge Disco Stu and Abu finally filed a complaint
before the Labor Arbiter for illegal dismissal, underpayment of wages, payment of backwages,
severance pay, 13th month pay and service incentive leaves, return of cash bond, as well as prayer for
award for moral and exemplary damages, and attorneys fees.
Draft a position paper in support of the complaint of Marge, Disco Stu and Abu.