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REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF LABOR AND EMPLOYMENT
NATIONAL LABOR RELATIONS COMMISSION
NATIONAL CAPITAL REGION
QUEZON CITY

DANILO MORENO TAYAO, JR.

Complainant,

-versus- NLRC CASE NO. NCR.01-00675-15

PRIME PEOPLE MULTI-PURPOSE

COOPERATIVE, DOKTORS GENERICS
PHARMACY INC., FRANKLIN MANILA,
CHARITY MARIE ROMARATE, HARRIER
ONGSUN, MENERVA RAMOS AND
RODEL SAN ANTONIO
Respondents,
x------------------------x

MOTION FOR WRIT OF EXECUTION

COMPLAINANT, by counsel, to this Honorable Commission, most

respectfully avers:

1. On 30 July 2015, the Honorable Labor Arbiter ZOSIMA C.

LAMEYRA rendered its Decision/Resolution in the above caption case.
The dispositive portion of the Decision/ Resolution stated, thus:

“WHEREFORE, premises considered, judgment is hereby

rendered that:
1. Employer-employee relationship existed between
Doktors Generics Pharmacy, Inc. and complainant;
2. Complainant was illegally dismissed;
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3. Respondent Doktors Generics Pharmacy Inc.is liable

to pay complainant the following:
a. Separation pay in the amount of Thirty-five
Thousand One Hundred Seventy-Eight
(P35,178.00)
b. Limited backwages from 28 November 2014
until the promulgation of this Decision in the
amount of One Hundred Nine Thousand Two
hundred Forty-eight Pesos and 90/100 (P109,
248.90)
c. 13th month pay in the amount of Thirty-Two
Thousand One Hundred Five Pesos and
74/100 (P32,105.75), and;
4. Attorney’s fees at ten (10%) percent of the total
monetary award in the amount of Seventeen
Thousand Six Hundred Fifty-Three Pesos and
26/100 (P17, 653.26).

SO ORDERED.”

2. Pursuant to Articles 223 of the Labor Code, as amended and

under Section 1, Rule VI of the 2011 NLRC Rules of Procedure,
“Decisions, awards, or orders of the Labor Arbiter are final and executory
unless appealed to the Commission by any or both parties within ten (10)
calendar days from thereof, X X X”.

3. To this date, respondents did not appeal the same.

4. Accordingly, the decision has become final and executory;

PRAYER

WHEREFORE, premises considered, herein complainant

respectfully pray that a Writ of Execution from this honorable Office be
issued based on the judgment/decision rendered by the Honorable Labor
Arbiter ZOSIMA C. LAMEYRA dated 30 July 2015, as follows:
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A. to pay Complainant DANILO MORENO TAYAO, JR. the

following:

a. Separation pay in the amount of Thirty-five

Thousand One Hundred Seventy-Eight
(P35,178.00)
b. Limited backwages from 28 November 2014
until the promulgation of this Decision in the
amount of One Hundred Nine Thousand Two
hundred Forty-eight Pesos and 90/100 (P109,
248.90)
c. 13th month pay in the amount of Thirty-Two
Thousand One Hundred Five Pesos and
74/100 (P32,105.75), and;
d. Attorney’s fees at ten (10%) percent of the total
monetary award in the amount of Seventeen
Thousand Six Hundred Fifty-Three Pesos and
26/100 (P17, 653.26).

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

Makati City for Quezon City, Metro Manila, September 23, 2015.

ATTY. REMEGIO C. DAYANDAYAN, JR

Counsel for Complainants
3rd flr. Universal Re: bldg.
Paseo De Roxas Makati.
Tel. Nos. 813-5238/892-3052 to 58
PTR No. 2194940/01.09.2015 Makati
IBP No.978762/12.17.14 Quezon City
Roll of Attorney’s No. 55149
3rd MCLE Compliance No. 0015516; May 04,
2010; MCLE 4th Compliance No. 0025696;
March 07 2013
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NOTICE OF HEARING

Greetings:

Please submit the foregoing motion for approval and consideration

of this Honorable Office immediately upon receipt hereof.

REMEGIO C. DAYANDAYAN, JR

Copy furnished:

Prime People Multi-purpose Cooperative

Unit 3b C and E Bldg. 26 Mindanao Ave.
Tandang Sora, Quezon City, Metro Manila

Doktors Generics Pharmacy Inc.

2nd floor, Lawyer’s Cooperative Building,
458 Quezon Ave., Quezon City, Metro Manila

EXPLANATION

The copies for Prime People Multi-purpose Cooperative and

Doktors Generics Pharmacy Inc. were served by registered mail due to
distance, time constraint and lack of office messengerial personnel.

REMEGIO C. DAYANDAYAN, JR