Republic of the Philippines

NATIONAL LABOR RELATIONS COMMISSION

Sub-Regional Arbitration Branch No. VII
Dumaguete City

NLRC RAB-VII-

Complainant,

-versus-

Respondents.
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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