Republic of the Philippines

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION
National Capital Region
Quezon City

ARNOLD E. DAGURO, et al.

Complainants,

- versus - NLRC NCR CASE NO. 12-00995-19

FREY FIL CORP.

Respondent.
x---------------------------------x

NOTICE OF APPEARANCE WITH

MOTION FOR EXTENSION OF TIME
TO FILE POSITION PAPER OF COMPLAINANT
Complainants Gaudencio M. Banayad, Mardy D. Martirez, Reny Boy P.
Nepacina, Renier B. Salva, Jessie S. Solinap, Christopher L. Mariano, Orlando
S. Lambus, Fil Am T. Amahit, Maria Cristina C. Layson, and Dalmacio V. Dela
Cruz, by and through the undersigned counsel and unto this Honorable
Commission, most respectfully avers:

1. That the services of the undersigned counsel was contracted only

last Wednesday, February 5, 2020.

2. That complainants were ordered to submit Position Paper on

February 10, 2020;

3. However, due to the pressures of equally urgent professional

work and prior commitments, the undersigned counsel will not be able to
meet the said deadline;

4. As such, undersigned counsel is constrained to request for an

additional period of ten (10) days from today or until February 20, 2020
within which to submit complainants’ Position Paper. Moreover, this
additional time will also allow the undersigned to study this case further and
in fact, there are other documents that he is requiring which are not yet
available;

5. This Motion is not intended for delay but solely due to the
foregoing reasons.

1
 PRAYER
WHEREFORE, it is most respectfully prayed of this Honorable
Commission that complainants be allowed extension of time to submit
Position Paper.

Respectfully submitted.

Makati City for Quezon City, February 10, 2020.

H.T. VILLEGAS LAW OFFICE

Unit C 3rd Floor LTA Bldg.,
118 Perea St., Legaspi Village
Makati City
Tel No. (02) 8451039

By:
KENN HENRI C. VILLEGAS
Privilege Tax Receipt No. 6988095
January 31, 2020, Iloilo City
IBP Receipt No. 087172
May 10, 2019, Pasig City
Roll No. 73221, June 18, 2019
MCLE Compliance Certificate No. VI – (exempt)

Copy furnished:

FREY FIL Corp.

83 West Ave., Brgy. Paltok,
San Francisco Del Monte,
Quezon City