Republic of the Philippines

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION
Regional Arbitration Branch No. 02
Tuguegarao City, Cagayan

ROWEL SEBASTIAN UNABIA,

Represented By: Melvin S. Unabia,
Complainant-
Appellee,
NLRC LAC No.__________
NLRC CASE NO. 10-00482-
- versus - 2019 OFW (M)

JDA INTERPHIL MARITIME

SERVICES CORP., AND/OR
JIMMY S. CASTILLO,
Respondents-
Appellants.
X---------------------------------------------------X

MOTION TO ADMIT REPLY

(To the Respondents’ Notice of Appeal With Memorandum of Appeal)

With utmost courtesy unto this Honorable Office, Complainant-

Appellee, through the Public Attorney’s Office, most respectfully submit
this Motion to Admit Reply and, humbly states THAT:

1. On November 5, 2020, Complainant-Appellee, through

counsel, received a copy of the Respondents-Appellants’ Notice of Appeal
With Memorandum of Appeal via a registered mail;

2. Upon review and perusal of the record, Complainant-

Appellee’s deemed it necessary to rebut the allegations of the respondents-
appellants which however, failed to timely files a reply, in view of the fact
that the Public Attorney’s Office, Cabagan, Isabela was devastated by the
massive flooding caused by the Typhoon “Ulysses”;

3. Thus, with utmost humility and candidness, Complainant-

Appellee is begging for compassion, mercy, and understanding of this
Honorable Office to admit the allegations in the attached Reply
and considered in whatever decision or resolution that the Honorable Office
may soon render in the interest of justice;

4. It is never the intention of the Complainant-Appellee to trifle

with the processes of this Honorable Office and this motion is not intended
1
to delay the proceedings of this case but solely due to the reason above-
stated.

WHEREFORE, it is most respectfully prayed that this humble

motion be GRANTED and that the attached Reply be ADMITTED and the
allegations therein be considered in the rendition of Decision or Resolution
in the above captioned case.

Other relief just and equitable under the premises are also most
respectfully prayed for.

Cabagan, Isabela for Tuguegarao City, Cagayan, December 2, 2020.

Department of Justice
PUBLIC ATTORNEY’S OFFICE
Cabagan District Office
Cabagan, Isabela

BY:

Atty. NICANOR G. GARCIA

District Public Attorney

Atty. JHOEY C. BUENO

Public Attorney

Copy furnished:

Atty. KRISTINA CAROL A. BAUTISTA

DEL ROSARIO & DEL ROSARIO LAW OFFICES
Counsel for the Respondents-Appellants
14th Floor, Del Rosario Law Centre
21st Drive corner 20th Drive
Bonifacio Global City
1630 Taguig, Metro Manila

ZAMIL OFFSHORE SERVICES Co.

PO. Box 749, Rahima 31941, KSA

EXPLANATION

A copy of this Motion to Admit Reply was served via registered mail,
instead of personal service, due to distance and time constraints and lack of
messengerial personnel.

2
 ATTY. JHOEY C. BUENO