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Motion For Execution of Judgment

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Raphael Rivas
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22 views

Motion For Execution of Judgment

Uploaded by

Raphael Rivas
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

Department of Labor and Employment


NATIONAL LABOR RELATIONS COMMISSION
Regional Arbitration Branch 10
Cagayan de Oro City

SAMUEL BOROY JENABE & NLRC CASE NO. RAB-10-10-00552-2020


ELEUNIDO SALAGUSE
Complainants,

-versus-

CANDOLE LABOR CONTRACTING


SERVICES & or DARIO S. CANDOLE(Owner)
OF QUIKFUN CORPORATION &/or HEYZUL LIM/HR
Respondents

x----------------------------------------------------------------------------------/

MOTION TO RELEASE JUDGMENT

COMES NOW, the Complainants, through the undersigned counsel and


to this Honorable Commission, respectfully alleges that:

1. That Judgment was rendered by this Honorable Commission in favor of


the Complainants on 28 May 2021. A copy of the Decision is hereto
attached as ANNEX “A” to “A-5”;

2. That said Judgment was duly received by the Respondents on 25


August 2021 as shown in the registry return card. A copy of the Notice of
Judgment/Decision and its Registry Return Card is hereto attached as
ANNEX “B” to “B-1”;

3. That a Letter by the Complainants was duly received by the


Respondents for the compliance of the Decision to report to work in order
not to abandon work; that parties herein agree that complainants chose to
be indemnified instead, as per the Decision, rather than return to work. A
copy of the Letter dated July 15, 2021 is hereto attached as ANNEX “C”;

4. That up to date, the Respondents have not filed any motion for
reconsideration or have appealed from said Decision, hence the Decision
has become final and executory;

5. Subsequently, a Motion for Execution dated July 11, 2022 had been filed
to this Honorable Commission. Attached hereto as ANNEX “D”to“D-2”;

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6. In response to the above-mentioned Motion for Execution, an Order
dated September 22, 2022 was rendered by the Honorable Commission to
enforce the monetary award of the Decision. A copy of said Order is
attached herein as ANNEX “E to “E-3-.”

WHEREFORE, premises considered, it is respectfully prayed that the


Judgment be released in favor of the Complainants.

Other reliefs and remedies that are just and equitable under the premises
are likewise prayed for.

RESPECTFULLY SUBMITTED
Cagayan de Oro City, Philippines, November 24, 2022.

RESPECTFULLY SUBMITTED.

By:

ATTY. CYRIL FRANCIS S. CASIÑO


Counsel for the Complainants
MGC Law Firm
Suite # 3, 2nd Floor Rego Building
296 Agoho Drive, Zone 1 Carmen,
Cagayan de Oro City

Copy Furnished:

Mr. Dario S. Candole, Owner


CANDOLE LABOR CONTRACTING SERVICES
Zone 6, Balite Street, Bugo, Cagayan de Oro City

Mr. Heyzul Lim, HR


QUIKFUN CORPORATION
Zone 7, Diversion Road-Opol
Misamis Oriental

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