REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF LABOR AND EMPLOYMENT

NATIONAL LABOR RELATIONS COMMISSION
Sub-Regional Arbitration Branch No.V
City of Naga

NESTOR J. IRANG, ET.AL.,

Complainant,

- versus - NLRC Case No. SRABV-10-00140-17 & 10-00142-17;

10-00143-17; 10-00144-17 and 10-00149-17

LANTING SECURITY &

WATCHMAN AGENCY/
ALBERTO S. LANTING,
Respondent/s.
x- - - - - - - - - - - - - - - - - - - x

M O T I O N
(To consolidate cases)

RESPONDENT/S, in the afore-entitled cases, by and through

the Undersigned Counsel and before the Honorable Office,
respectfully pleads that he be allowed to consolidate all these various
cases pending before HONORABLE EXECUTIVE LABOR ARBITER
JOSE C. DEL VALLE, JR., in support thereof, respectfully avers:

1. Respondent has several Labor Cases against him before

the Honorable Office, which are entitled and docketed as above
cited.

2. These cases are founded on the same facts or forming

part of series of acts of similar character may be tried jointly at the
discretion of the Court.
 3. The parties were now ordered to file their respective
Position Papers before the Honorable Arbiter.

4. To make things easier and less expensive for the parties,

who still come from Metro Manila, the Respondent indulged your
kind consideration to have the cases be consolidated into one
before the Honorable Arbiter.

5. This is for human compassion that there is a paramount

necessity for Respondent to pray for this consideration.

WHEREFORE, premises considered, it is respectfully prayed of

the Honorable Office that:

a. This Motion be given its due weight and credence;

b. The above-cited case be consolidated before Hon.
Executive Labor Arbiter Jose C. Del Valle, Jr.

Other reliefs and remedies just and equitable under the

premises are likewise prayed for.

City of Manila for City of Naga, November __, 2017.

ATTY. ROMEO N. BARTOLOME

Counsel for the Respondents
Unit 2-C, 2nd Floor, Dahlia Tower
Suntrust Parkview Condominium
No.181 N. Lopez St., Ermita, Manila
IBP No.1006009/1-05-17/Mla.
PTR No. 6003227/1-05-17/Mla.
Roll No. 37717
MCLE Compliance No. V-0003125
July 25, 2014

NOTICE
Hon. Executive Labor Arbiter Jose C. Del Valle, Jr.
National Labor Relations Commission
Sub-Regional Arbitration Branch No.V
City of Naga

Mr. Nestor J. Irang, et.al.

P-9. Larap, Jose Panganiban,
Camarines Norte

Greetings!

Please take notice that Undersigned Counsel will submit the

foregoing Motion for the kind consideration and approval of the
Honorable Court on __________, 2017 at _______.

ATTY. ROMEO N. BARTOLOME

EXPLANATION

This is to certify as an officer of the court that a copy of the

MOTION was served not by personal service, but through registered
mail by reason of time constraint, distance, lack of manpower and/or
urgency.

ATTY. ROMEO N. BARTOLOME

Copy furnished:

Mr. Nestor J. Irang, et.al.

P-9. Larap, Jose Panganiban,
Camarines Norte