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Motion To Release Bail Bond

The document is a motion filed with the National Labor Relations Commission requesting a writ of execution and the release of a bond. It summarizes that a previous decision in favor of the complainant was reversed by the NLRC but later reinstated by the Court of Appeals and Supreme Court, making the judgment final and executory. The motion asks the NLRC to issue a writ of execution against the respondents and order the release of a PHP 531,383 bond held in the complainant's favor.

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Alexylle Garsula de Concepcion
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406 views3 pages

Motion To Release Bail Bond

The document is a motion filed with the National Labor Relations Commission requesting a writ of execution and the release of a bond. It summarizes that a previous decision in favor of the complainant was reversed by the NLRC but later reinstated by the Court of Appeals and Supreme Court, making the judgment final and executory. The motion asks the NLRC to issue a writ of execution against the respondents and order the release of a PHP 531,383 bond held in the complainant's favor.

Uploaded by

Alexylle Garsula de Concepcion
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

NATIONAL LABOR RELATIONS COMMISSION


Sub-Regional Arbitration Branch No. VII
Dumaguete City

NLRC RAB-VII-

Complainant,

-versus-

Respondents.
x------------------- ----
-/

MOTION FOR A WRIT OF EXECUTION AND


MOTION TO RELEASE BOND
Complainant, by counsel, unto this Honorable Commission,
respectfully states:

1. That on _____________, the Honorable Court of Appeals


resolved that, the Decision of the NATIONAL LABOR
RELATIONS COMMISSION (NLRC) dated
______________ and its Resolution dated
______________ were REVERSED and SET ASIDE.

Further, the Decision of the Labor Arbiter dated


_______________ is REINSTATED. That said Machine
copy of which is hereto attached as Annex A and made
integral part hereof;

2. That on _____________, the Honorable Supreme Court


resolved to DENY the petition for failure to sufficiently
show that the Court of Appeals committed any reversible
error in the challenged decision and resolution as to
warrant the exercise of this Courts discretionary appellate
jurisdiction.

Further, the complainant through counsel received a copy


of the decision on __________. Machine copy of which is
hereto attached as Annex B and made integral part
hereof;
3. That the judgment on the above-entitled case has
become FINAL and EXECUTORY on ______________.
Machine copy of which is hereto attached as Annex B
and made integral part hereof;

4. That by virtue of the Decision by the Supreme Court Third


Division dated _________________ and Entry of
Judgment dated ____________:

a. Complainant moved for the issuance of a Writ of


Execution against respondents. Machine copies of
which are hereto attached as Annexes C and B;

b. Complainant moved for the release of Bond in


Managers Check No. 000000, pay to the order of
NLRC in the amount of FIVE HUNDRED THIRTY ONE
THOUSAND AND THREE HUNDRED EIGHTY
THREE PESOS (PHP 531, 383.00). Machine copy of
which are hereto attached as Annex D

PRAYER

WHEREFORE, the Honorable Commission is most respectfully


prayed to issue a writ of execution against the respondents and order
the NLRC Cashier to accordingly cause the release of Bond in favor
of the complainant the adjudged monetary award.

Complainant prays for other reliefs just and equitable under the
premises.

Respectfully submitted.

Makati City, Philippines, ____________.

JUAN DELA CRUZ


Counsel for Complainant
IBP No. 1000000; 12/29/15
PTR No. 1000000; 01/04/16
Roll of Attorneys No. 50000
MCLE Compliance No. V-
0000000
Street, Makati City
Tel. No.

THE HONORABLE LABOR ARBITER


Dumaguete City

Greetings.

Please take notice that the undersigned is kindly submitting the


same for hearing on ____________ at 9:00 oclock in the morning at
the usual place of session.

JUAN DELA CRUZ

Copy furnished by registered mail:

ATTY. PEDRO PENDUKO


Counsel for Respondents

Registry receipt no.: ________________ on March ____, 2017

DIVE AND REST RESORT


Lipayo, Dauin, Negros Oriental

Registry receipt no.: ________________ on March ____, 2017

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