Republic of the Philippines

NATIONAL LABOR RELATIONS COMMISSION

Regional Arbitration Branch No. VII
Cebu City

BERNARDINO S. POSTRERO,
Complainant,

-versus- NLRC RAB-VII CASE

NO.11-2072-17

STO. NIÑO VILLAGE HOMEOWNERS

ASSOCIATION, INC.,
Respondent.
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URGENT EX-PARTE MOTION TO

ADMIT AMENDED COMPLAINT

COMPLAINANT, Bernardino s. Postrero through his undersigned

counsels, unto this Honorable Commission, most respectfully sets forth:

1. That the complainant has filed a complaint before the

National Labor Relations Commission on November 6, 2017. The case
was then set for hearing on November 20 and 27, 2017 at 9:00 AM. The
undersigned counsels were directed to file a position paper on December
12, 2017 at 2:00PM;

2. Upon careful interview of the complainant, it was discovered

that the complainant failed to claim for Nominal Damages, Moral
Damages, Exemplary Damages and Attorney’s Fees in the Complaint that
he filed on November 6, 2017;

3. In view of the foregoing circumstance and for the better

interest of justice and equity, we would like to move for the admission of
the amended complaint, since the respondent has not yet filed their
respective answer or position paper;

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 4. The Motion to admit the amended complaint is for the interest
of the complainant for the counsels to properly defend his rights. It is not
intended for delay.

PRAYER
WHEREFORE, premises considered, the undersigned Movant
therefore beseech the benevolence of the Honorable Labor Arbiter to
GRANT the urgent ex-parte motion to admit the amended complaint in
furtherance of justice.

Respectfully Submitted.Cebu City, Philippines, December 12, 2017.

CABRERA SIPALAY MAYOL SALAS & BACALSO

LAW OFFICES
Counsel for the Complainant
Room 206, Aniceta Bldg.,
Osmeña Blvd., Capitol Site, Cebu City
Tel. No. (032) 255-7476 ; Fax No. (032)255-2872
By:

ALFREDO J. SIPALAY
Counsel for the Complainant
IBP No. 1058995; 1-03-17; Cebu City
PTR No. 13262067; 1-03-17; Cebu Province
Attorney’s Roll # 36962
MCLE Compliance No. V-0003632/09-08-14

ATHENA M. SALAS
Counsel for the Complainant
Roll of Attorneys No. 65125
IBP No. 015117; Lifetime; June 17, 2016
PTR No. 13258842; December 5, 2016; Cebu Province
MCLE Compliance B.O No.1 Series of 2008

Copy Furnished:

Counsel for the Respondent:

Received by: __________________

Date:_______________________

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