Labor and quasi-judicial

Draft an NLRC position paper under the 2025 Rules.

The position paper is where a labour case is actually won or lost: it carries the causes of action, the documents and the witnesses’ affidavits, which take the place of direct testimony. Its hardest rule is a limiting one — a claim raised for the first time in the position paper is not entertained, so anything not pleaded in the complaint is already gone.

Court pleading 5 required elements Cites retrieved authority 5 credits

How to draft this

Four steps from a sentence to a Word file.

  1. 01

    Describe the document in one sentence

    Type what you need in plain language — "draft an NLRC position paper" plus the facts you already have. No template to hunt, no blank Word file to start from.

  2. 02

    Generate the first draft

    BatasDB matches the request to an NLRC position paper and writes it against the 5 required elements on this page, citing only authority retrieved from the library.

  3. 03

    Fill the marked blanks

    Names, dates, amounts and other facts you did not supply come back as marked blanks, counted at the top of the draft. Rewrite freely in the editor.

  4. 04

    Export to Word or PDF

    Export with the unfilled blanks highlighted. Editing, exporting and duplicating are free — only generating a new draft uses credits.

Drafted from

2025 NLRC Rules of Procedure, Rule V, Sec. 11 (En Banc Resolution No. 09-25)

This is the retrieval hint BatasDB searches the library with, and the anchor for the checklist below. It is never emitted into your draft as a citation: the draft may cite only what retrieval actually returned, plus any provision you named yourself.

The checklist

What an NLRC position paper has to contain.

These are the elements BatasDB drafts against — injected into the generation itself, not checked afterwards. Where you have not supplied what an element needs, the draft leaves a marked blank instead of writing something plausible.

  1. 01

    Only the claims in the complaint

    Causes of action limited to those pleaded in the complaint. A claim raised for the first time here is not entertained.

  2. 02

    Verification

    The position paper must be verified.

  3. 03

    All supporting documents

    Attached, not merely described.

  4. 04

    Witnesses’ affidavits

    Which take the place of their direct testimony.

  5. 05

    The familiar skeleton — labelled as convention

    Caption, statement of facts, issues, discussion, prayer. The draft says plainly that this structure is practice convention and not a rule-prescribed one, rather than presenting a house style as a requirement.

Before it drafts

Drafted under the 2025 NLRC Rules

Every position-paper draft carries an advisory naming the 2025 NLRC Rules of Procedure (En Banc Resolution No. 09-25) as the governing procedure, so the draft is not silently written against the superseded rules.

Not written by the AI

The formal parts are assembled, not generated.

The scaffolding an NLRC position paper needs is appended by the app from the rule that requires it. The drafting model does not write these and is explicitly told not to, so they cannot drift, be paraphrased, or come out subtly wrong.

  • the prayer, "RESPECTFULLY SUBMITTED", and counsel’s signature block
  • copy furnished
  • the verification and its jurat

What it leaves to you

The gaps are marked, not filled.

Facts you did not supply

Every name, date, amount, docket number and address you did not give comes out as a marked blank — [FACT NEEDED: …] — rather than as a plausible invention. They are counted at the top of the draft and highlighted in the Word and PDF exports.

Assertions it made on its own

A gate reads the drafted text for concrete assertions that trace back to nothing you said and nothing that was retrieved, and rewrites each as [CONFIRM: …] for you to check before you sign.

The judgment

Every draft carries a standing notice: AI-generated draft — review before filing or signing. Not legal advice. It is a first draft for a lawyer, not a filing-ready document.

FAQ

NLRC Position Paper: questions lawyers ask.

Can I raise a new claim in the position paper?
No. Causes of action are limited to those pleaded in the complaint, and a claim raised for the first time in the position paper is not entertained. The checklist BatasDB drafts against states this as a hard limit.
Do witnesses testify at the NLRC?
Their affidavits take the place of direct testimony, which is why the position paper carries them as attachments rather than promising testimony later.
Which NLRC rules does the draft follow?
The 2025 NLRC Rules of Procedure, Rule V, Sec. 11, adopted by En Banc Resolution No. 09-25. Every draft states the governing procedure explicitly rather than leaving you to check whether it used the old rules.

Start from a draft that already read the rule.

Describe your NLRC position paper in a sentence, fill in what only you know, and export it to Word or PDF.

Uses 5 credits from your monthly allowance — editing and exporting are free. See plans →

Draft this document