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Republic of the Philippines

Department of Labor and Employment


NATIONAL LABOR RELATIONS COMMISSION
Regional Arbitration Branch No. III
City of San Fernando, Pampanga

Hon. LEANDRO M. JOSE


Labor Arbiter

MERCEDITA C. MENDOZA,
Complainant,

- versus - NLRC CASE NO. RAB-III-03-23879-16

VAG GENERAL MERCHANDISE


KRISLYN C. MANGALINDAN &
MR. VICTOR GADDI,
Respondents.
x----------------------------------------------x

MOTION
FOR THE ISSUANCE OF A WRIT OF EXECUTION

COMPLAINANT, assisted by the Public Attorney’s Office through the


undersigned counsel and unto this Honorable Office, respectfully states the
following:

1. In the Decision dated 17 June 2016 penned by the Honorable


Leandro M. Jose, the dispositive portion reads as follows:

“WHEREFORE, premises considered, complainant is found to


have been illegally dismissed even as respondents are hereby held
liable therefor.

Consequently, respondents are hereby ordered to pay


complainant her full backwages from the time nof her dismissal
until the finality of this decision, initially computed at this time at
Php137,199.98.
2

Respondents are likewise ordered to pay complainant her


separation pay of Php30,000.00, 13th month pay (pro rata) of
Php25,000.00; Unpaid Wages of Php90,000.00 and 10% attorney’s
fee of Php28,219.99.

All other claims are hereby dismissed for lack of merit.

So Ordered.”

2. A copy of the above Decision was received by the Complainant,


through counsel, on 11 July 2016. Said decision became final and executory last
10 August 2016. A copy of the Certificate of Finality is attached herewith as
Annex “A.”

3. Considering the finality of the above Decision, Complainant


respectfully moves for the issuance of a writ of execution for the satisfaction of
the above monetary judgment rendered in her favor.

WHEREFORE, premises considered, it is respectfully prayed unto this


Honorable Office that a writ of execution be issued for the satisfaction of the
monetary judgment in the Decision dated 17 June 2016.

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

CSJDM, Bulacan for San Fernando, Pampanga. 26 September 2016.

Department of Justice
PUBLIC ATTORNEY’S OFFICE
City of San Jose Del Monte, Bulacan District Office
2nd floor Gilles Building, Brgy. Graceville
City of San Jose Del Monte, Bulacan

By:

RAPHAEL JOSEPH B. SEARES


Counsel for the Complainant
Public Attorney III
Roll No. 58097 (Manila III)
MCLE Compliance No. V-0013227/1-19-2016
IBP Lifetime No. 011426/1-22-2013
3

NOTICE of HEARING
(And copy furnished to:)

Ms. KRISLYN C. MANGALINDAN


Mr. VICTOR GADDI
VAG General Merchandise
Barangay Gutad, 2006 Floridablanca
Pampanga

Please take notice that the foregoing motion will be submitted for the kind
consideration and approval of this Honorable Office immediately upon receipt
hereof.

RAPHAEL JOSEPH B. SEARES

EXPLANATION
(Pursuant to Sec. 11, Rule 13 of the 1997
Rules of Civil Procedure)

The foregoing motion is being served by registered mail due to distance


and lack of messengerial personnel.

RAPHAEL JOSEPH B. SEARES

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