Scribd
Upload
784 views

Motion To Revive The Case and Admit Position Paper

The document is a motion filed by a complainant with the National Labor Relations Commission Regional Arbitration Branch requesting that their case be revived and their position paper be admitted. The case was dismissed without prejudice due to the parties' failure to submit verified position papers by the deadline. However, the initial order requiring the position paper was unsigned. The complainant is asking the court to interpret the rules in their favor and allow the late submission of the position paper to protect the complainant's interests as a laborer.

Uploaded by

DennisSayco
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
784 views

Motion To Revive The Case and Admit Position Paper

The document is a motion filed by a complainant with the National Labor Relations Commission Regional Arbitration Branch requesting that their case be revived and their position paper be admitted. The case was dismissed without prejudice due to the parties' failure to submit verified position papers by the deadline. However, the initial order requiring the position paper was unsigned. The complainant is asking the court to interpret the rules in their favor and allow the late submission of the position paper to protect the complainant's interests as a laborer.

Uploaded by

DennisSayco
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
You are on page 1/ 2

Republic of the Philippines

Department of Labor and Employment


NATIONAL LABOR RELATIONS COMMISSION
Regional Arbitration Branch No XX
Chui Ave. Wadab City
-oOo-

XXXXXXXXXXXXXXXXXX NLRC RAB-XX-XXXXX-X


Complainant

-vs- FOR: ILLEGAL DISMISSAL with


MONEY CLAIMS

XXXXXXXXXXXXXXXXX
Respondents
x----------------------------------------------x

MOTION TO REVIVE THE CASE and ADMIT POSITION


PAPER

COMES NOW, the Complainant XXXXXXXXXXXXXXXXXXX with the


assistance of the XXXXXXXXXXXXXXX, unto this Honorable Quasi-judicial
Body, most respectfully avers:

1. That the Complainant belatedly filed a Position Paper on XX March 2019


before this Honorable Body. The latter date is based on the Order dated
XX February 2019 giving the Complainant to file a Position Paper for
Ten (10) days from receipt thereof. The said Order however, was
unsigned by the Labor Arbiter XXXXXXXXXXXX. The Complainant
was then asked by the lawyer handling the case to have the same verified
for signature since this representation submits that an unsigned Order is
just a mere scrap of paper. Attached hereto is a photocopy of the Order
dated XX February 2019 as Annex “A”;

2. That pursuant to an Order of this Honorable Quasi-judicial Body dated


XX March 2019, this case was ordered DISMISSED WITHOUT
PREJUDICE to refiling the same. The case was dismissed for the parties’
non-compliance to the Order for the submission of verified position
papers undersigned on XX February 2019;

3. That the Complainant is pleading before this Honorable Body to


REVIVE and to ADMIT the Position Paper by the Complainant since the
initial Order requiring the Complainant to file a position paper was
unsigned;

4. Henceforth, the Complainant is asking that the Rules of this Honorable


Body be interpreted and applied in his favor to protect his interest as a
laborer.

WHEREFORE, it is most respectfully prayed that the Complainant in this


particular case be allowed to submit his position paper despite of lapse of time
given to him and; that the said motion be dutifully submitted immediately for the
consideration and resolution of this Honorable Court.
4 April 2019, Wadab City, Davao del Norte, Philippines.

NOTICE OF HEARING

HON. XXXXXXXXXXXXXXXXXXXX
Labor Arbiter
National Labor Relations Commission – RAB No. XXX
Wadab City

Ms. XXXXXXXXXXXXXXXXXX
Respondent

Greetings!

Please be informed that I am submitting the foregoing motion immediately


upon receipt hereof without further oral argument and appearance of counsel.

DENNIS C. SAYCO

Copy Furnished:
HON. XXXXXXXXXXXXXXXXXXXX
Labor Arbiter
National Labor Relations Commission – RAB No. XXX
Wadab City

Ms. XXXXXXXXXXXXXXXXXXXXX
Respondent
Brgy. XXXXXXXXXX
Wadab City

You might also like

pFad - Phonifier reborn

Pfad - The Proxy pFad of © 2024 Garber Painting. All rights reserved.

Note: This service is not intended for secure transactions such as banking, social media, email, or purchasing. Use at your own risk. We assume no liability whatsoever for broken pages.


Alternative Proxies:

Alternative Proxy

pFad Proxy

pFad v3 Proxy

pFad v4 Proxy