Republic of the Philippines

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION
National Capital Region - Quezon City

JOEL G. SALAZAR III, NLRC OFW NCR Case No. [M] 06-01-00264-00
Complainant, Hon. L.A. Ramon Valentin C. Reyes

- versus - NLRC CA. No. ________________________

3RD Division
SKIPPERS UNITED PACIFIC, INC.,
AEGEAN BUNKERING SERVICES,
(CARMEL INVESTMENT CORP.),
& RAMONA G. SALCEDO,
Respondents.
x------------------------------------------------------x

MANIFESTATION WITH MOTION

TO RESERVE AND ENFORCE ATTORNEY’S LIEN

Undersigned, erstwhile counsel for complainant Joel G. Salazar III, before this Honorable
Labor Arbitration Office, respectfully manifests –

1. Complainant enlisted the services of another lawyer without meeting and informing
undersigned that he is formally terminating the legal services ably rendered to him.

2. The fact stands on the record of the above-captioned case that undersigned counsel
rendered all necessary legal services at the level of this Honorable Arbitration Office.
Undersigned attended the mandatory conferences; did the legal works from research to
preparation and filing of the “Position Paper”, “Reply” and “Rejoinder” for and on-behalf of
complainant, with the approval of the complainant. As a matter of fact, the case has been
decided in complainant’s favor on the basis of all the pleadings and documents filed by
undersigned counsel and the respondents.

3. The complainant did not pay even a single centavo to undersigned counsel in the midst of
appropriate legal services rendered to him. Moreover, it was even undersigned counsel
who paid the expenses of documentation, printing, photocopying, mailing,
telecommunications, gasoline for transport, and meals while the pleadings were prepared,
served to adverse counsel, and eventually filed at this Honorable Arbitration Branch.

4. In the interest of justice, it is respectfully submitted that the contingent attorney’s fees
constituting a lien on the judgment award given in favor of complainant must be preserved
and enforced at any appropriate time if and when complainant is paid either voluntarily by
 Manifestation with Motion
Page 2 of 3
------------------------------------

respondents or their representatives, or if warranted under the circumstances in the near

future, then by way of compulsory processes.

5. Undersigned learned that complainant and his new counsel were recently attempting to
settle the claims with the representatives of respondents, before this Honorable Office.

RELIEF

WHEREFORE, in the interest of justice and fair treatment, it is respectfully asked that the
contingent attorney’s fees of undersigned counsel equivalent to ten [10%] of the judgment
award in favor of complainant plus an additional ten percent [10%] to cover expenses, or a total
of twenty percent [20%] thereof, be reserved and enforced by separating such amount at the
appropriate time, if and when complainant is paid either voluntarily by respondents or their
representatives, or if appropriate under given circumstances then by way of compulsory
processes in accordance with applicable laws and rules.

Other reliefs just and equitable are likewise respectfully sought.

RESPECTFULLY SUBMITTED.
Santa Cruz, Laguna for Quezon City, 28 July 2009.

Atty. EMMANUEL E. SANDICHO

IBP No. 739042, 8 Jan. 2009, ManilaIV
PTR No. 7362174, 9 Jan. 2009 Laguna
Roll No. 42246 admitted on 9 May 1997
MCLE Compliance No. II-0003972
Basic Christian International School and
Special Education Center, Incorporated
2nd Floor Kamatoy Building–Annex (7-11)
A. Bonifacio St. cor. P. Guevarra Avenue
Santa Cruz, Laguna 4009
 Manifestation with Motion
Page 3 of 3
------------------------------------

NOTICE
Atty. DENNIS LUIS B. CABANOS
DEL ROSARIO & DEL ROSARIO LAW OFFICE
15th Flr. Pacific Star Bldg., corner Makati and Gil
Puyat Avenues, Makati City, Metro Manila

OFFICE OF HON. RAMON VALENTIN C. REYES

National Labor Relations Commission (NLRC)
Rm. 315 3rd Flr. PPSTA Bldg., Banawe Avenue
Nr. cor. Quezon Avenue, Quezon City

Mr. JOEL G. SALAZAR III

2225 Callejon Felipa St., Batanes Ext., Sampaloc
Manila

Please take notice that undersigned will submit this manifestation with motion to reserve
and enforce attorney’s lien upon receipt hereof with or without personal appearance of
counsels.

Atty. EMMANUEL E. SANDICHO

Copy furnished, by way of registered mail, due to exigencies of distance, economy and time
constraints, personal service rendered impracticable therefore, to the following –--

DEL ROSARIO & DEL ROSARIO LAW OFFICE

15th Flr. Pacific Star Bldg., corner Makati and Gil Reg. Receipt No. __________
Puyat Avenues, Makati City Posted at ______ on ________

NATIONAL LABOR RELATIONS COMMISSION

THIRD DIVISION
PPSTA Bldg., Banawe Avenue nr. cor. Quezon
Avenue, Quezon City, Metro Manila Reg. Receipt No. __________
Sampaloc, Manila Posted at ______ on ________

Mr. JOEL G. SALAZAR III

2225 Callejon Felipa Street, Batanes Extension Reg. Receipt No. __________
Sampaloc, Manila Posted at ______ on ________

Atty. EMMANUEL E. SANDICHO