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Motion For Issuance of Order

This document is a motion filed in a labor case requesting the issuance of a dismissal order as the parties have settled the case amicably. It provides background on the joint motion for withdrawal and settlement filed with the NLRC, as well as annexes related to the settlement agreement and motion to declare the case closed.

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63 views2 pages

Motion For Issuance of Order

This document is a motion filed in a labor case requesting the issuance of a dismissal order as the parties have settled the case amicably. It provides background on the joint motion for withdrawal and settlement filed with the NLRC, as well as annexes related to the settlement agreement and motion to declare the case closed.

Uploaded by

sam espinas
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
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
Sub-Regional Arbitration Branch XII
Cotabato City

HTML dela Cruz,


Complainants-Appellees,

-versus- NLRC CASE NO. MAC-10-01XXXX-


17
BLUE GREEN HOMES INC.,
NLRC SUBRAB CASE NO XII-07-
Respondent-Appellant. 00056-17 TO XII-07-00059-17
x-----------------------------------x

URGENT MOTION FOR


ISSUANCE OF DISMISSAL ORDER

RESPONDENT-APPELLANT, through the undersigned


counsel, unto this Honorable Labor Arbiter most respectfully state
that:

1. On 28 February 2018, RESPONDENT-APPELLANT, through


counsel, and the COMPLAINANT-APPELLEES individually filed
before the National Labor Relations Commission (NLRC), Eight
Division a Joint Motion to Withdraw/Dismissal of the Case with
confirmation receipt of settlement amount on the ground that
the parties have decided to settle the case amicably. Copies of
which are hereto attached as ANNEX “A”, “A-1”, “A-2” and “A-3”.

2. The COMPLAINANT-APPELLEES also executed a


Quitclaim and Release with Motion to Dismiss dated 22
January 2018 which are annexed to the said joint motion to
withdraw. Copies of which are hereto attached as ANNEX “B”, “B-
1”, “B-2” and “B-3”.

3. Likewise, a Manifestation with Motion to Declare the


Instant Case Closed and Terminated was also filed before the
NLRC by the RESPONDENT-APPELLANT on 28 March 2018. Copy
of which is hereto attached as ANNEX “C”.
4. Hence, the Honorable National Labor Relations
Commission, Eight Division issued a resolution remanding the
instant case to the Sub-Regional Arbitration Branch XII.

5. However, until present, the Sub-Regional Arbitration


Branch has not yet issued an ORDER declaring the instant case to
be closed and terminated.

6. Thus, the RESPONDENT-APPELLANT’s Supersedeas Bond


with OIC Bond No. G-(11)XXXX82X PGA Bond No. BD-G15 HOM-
0XXXXXX6 which it posted when it appealed the case before the
NLRC has not yet been released.

7. Therefore, RESPONDENT-APPELLANT humbly moves for


the issuance of an order dismissing the above-captioned
complaints.

PRAYER

WHEREFORE, RESPONDENT-APPELLANT, most respectfully


prayed that this instant motion be duly NOTED and that an ORDER
declaring the instant case to be CLOSED and TERMINATED be duly
issued.

Other reliefs as may be deemed just and equitable under the


premises are likewise prayed for.

Makati City for Cotabato City, _____ October 2020.

TRESE KATORSE
Counsel for the Respondent
178-E Cor. Rizal Ave., Makati City
Tel nos. (02) 888-7788/ 7889928
Roll No. 00000
PTR No. MC699997; 1-2-2020; Makati City
IBP Number 09999-LIFETIME-02/13/1999
MCLE Compliance No. VV – 001222338/18-Jan-2018

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