Republic of the Philippines

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION
National Capital Region
Quezon City

HUBAJEB PALINIS BILIO,

Complainant,

-versus- NLRC-NCR CASE No. 03-04594-19

(Before L.A. Keneth Raphael E. Ybanez)

TESSIE’S FLOWERS SHOP JAR &

POTTERIES/TERESITA SOTTO,
Respondents,
x----------------------------x

MOTION FOR LEAVE TO

ADMIT POSITION PAPER

COMES NOW, Complainant by counsel before the Honorable Branch most

respectfully avers:

1. On May 31, 2019, the parties simultaneously filed their respective position
paper in compliance with the order the Honorable Labor Arbiter.

2. Through sheer ignorance, complainant filed and furnished the adverse

party his unsubscribed position paper and this was only noticed when he reported
to the undersigned office. He was however under instruction to subscribe the
position paper before the Honorable Labor Arbiter but the latter was not present
during the filing thereof.

3. Under the NLRC Rules of Procedures, position papers of parties must be

under oath in order to be considered in rendering the decision

4. Complainant is hereby filing and furnishing the adverse party the herein
attached duly notarized position paper in lieu of the previously filed and furnished
position paper.

5. This motion is not intended to delay the proceeding of the Honorable

Branch but solely for the purpose above stated.

PRAYER

WHEREFORE, It is most respectfully move that the herein attached duly

notarized position paper is admitted as part of the record of the case to be
considered and appreciated in rendering the decision.
1
 Other order and relief, just and equitable are likewise prayed for.

Quezon City, June 13, 2019.

Atty. Gregorio V. de Lima, Jr.

Counsel for Complainant
No. 6 Colonel Martinez Street,
West Avenue, Quezon City
PTR No.7447043, Jan. 11, 2019, Q.C.
IBP No.02633, Lifetime, Q.C.
Attorney Roll No. 26674
MCLE VI Taken last 04 April 2019

Copy Furnished:

Teresita Sotto
Respondent
Fugoso St. Sta Cruz Manila