REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF LABOR AND EMPLOYMENT

NATIONAL LABOR RELATIONS COMMISSION
REGIONAL ARBITRATION BRANCH NO.IV
CALAMBA, PROVINCE OF LAGUNA

MARK LUCIO R. BASA, JR.,

ET.AL.,
Complainants,
NLRC CASE NO.RAB-IV-01-00067-19-17-
B
NLRC CASE NO. RAB-IV-01-00066-19-L
NLRC CASE NO. RAB-IV-02-00219-19-L
-versus- NLRC CASE NO. RAB-IV-02-00219-19-L
NLRC CASE NO. RAB-IV-02-00281-19-B
PARAVISIBLE CONSTRUCTION,
INC./RODEL PABELETE,
Respondents.
X--------------------------------------X

MOTION FOR
ISSUANCE OF WRIT OF EXECUTION

COMPLAINANT, by counsel, unto this Honorable Office, most

humbly and respectfully moves that a Writ of Execution be issued in
favor of the Complainant-Movants in satisfaction of the judgment award
in support thereof, avers:
1. On July 14, 2020, the Honorable First Division of the National
Labor Relations Commission (NLRC) promulgated a decision “notgiving
due course to the appeal filed by the respondents Paravisible Builders,
Inc. and Rodel Pabalate and their motion to reduce the appeal bond
became moot and academic. Hereto attached is the Honorable
Commission’s Decision dated July 14, 2020 (ANNEX “A”).

2. We submit that the Honorable Executive Labor Arbiter’s

Decision dated October 30, 2019in the above-stated cases is already final
and executory As of September 9, 2020. No motion for reconsideration
was filed by the respondents. Instead a “Motion to Set Case for
Conference for Final Settlement was filed by respondents’ new counsel
Atty. Rosario Dolores V. Alday.
 3. However, in the above-mentioned decision, the Honorable
Executive Labor Arbiter computed the judgment award as the date of hid
Decision or October 30, 2019. To date, the Decision is already twelve (12)
months old and prudence dictates that a re-computation be made to
include this twelve (12) months or until October 15, 2020, for back
wages, separation pay and thirteenth month pay.

4. Hence, the re-computed amount should be as follows:

RE-COMPUTATION FOR A PERIOD OF 21 MONTHS FROM JANUARY 15, 2019 to OCTOBER 30, 2020
NAME RATE BACK WAGES 13th MONTH SEPARATION PAY TOTAL

(2019 and 2020)

MARK LUCIO Php 500.00 Php 273,000.00 Php 26,000.00 Php 26,000.00 (2 :Php325,000.00
BASA, JR. yrs)

ELMER DELA Php 500.00 Php 273,000.00 Php 26,000.00 Php 52,000.00 (4 :Php351,000.00
ROSA yrs)

RODOLFO Php 500.00 Php 273,000.00 Php 26,000.00 Php 52,000.00 (4 :Ph351,000.00
MAHINAY yrs)

JAY-R MAGO Php 550.00 Php 300,300.00 Php 28,600.00 Php 28,600 (2 yrs) :Php357,500.00

LEOPOLDO Php 550.00 Php 300,300.00 Php 28,600.00 Php 28,600.00 (2 :Php357,500.00
REYES yrs)

PHILIP Php 550.00 Php 300,300.00 Php 28, 600.00 Php 28,600.00 :Php357,500.00
EDWARD
(2 yrs)
BACCOL

MARLON Php 550.00 Php 300,300.00 Php 28,600.00 Php 57,200.00 :Php386,100.00
LIGAN
(4 yrs)

MARK Php 550.00 Php 300,300.00 Php 28,600.00 Php 28,600.00 :Php357,500.00
ANTHONY
(2 yrs)
ANTONIO

LITO CANDA Php 600.00 Php 327,600.00 Php 31,200.00 Php Php :Php 420.800.00
62,000.00 (4 yrs)

MILLER Php 650.00 Php 354,900.00 Php 33,800.00 Php 67,600.00(4 :Php456,300.00
LEGASPI yrs)

Php 3,003,000.00 Php 286,000.00 Php 431,200.00 Php 370,200,000.00

4. We submit that the In view of the foregoing, complainant

through the undersigned counsel most humbly and respectfully moves
for the issuance of a Writ of Execution in favor of the Complainant in the
re-computed amount of Php 3,720,200.00.
 PRAYER

WHEREFORE, premises considered, it is most humbly and

respectfully prayed of this most Honorable Office that a Writ of Execution
in the re-computed amount of Php 3,720,200.00.

Other reliefs and remedies which are just and equitable in the
premises are likewise prayed for.

OTHER RELIEFS, just and equitable under the premises are

likewise being prayed for.

Muntinlupa Cty City for Calamba City, Province of Laguna, October

__ , 2020.

FLORES TALENS ROMANILLOS LAW OFFICES

Counsel for the Respondents
Suite 506 South Center Tower
2206 Market Street Madrigal Business Park,
Ayala Alabang, Muntinlupa City

By:

ATTY. ARIS  J. TALENS

Counsel for the Complainants
Roll of Attorney No. 47352
IBP No. 105577– 01/09/20 - Laguna
PTR No. 2220665– 01/07/20 – Parañaque City
MCLE Compliance No. VI – 0019631 – valid until April 14, 2022

Copy Furnished:

ATTY. ROSARIO DOLORES V. ALDAY

Counsel for the Respondents
PARAVISIBLE BUILDERS, INC. /RODEL PABALATE
2?F Maicor Bldg., Taysan, San Jose Batangas 4227

PARAVISIBLE BUILDERS, INC.

RODEL PABALATE
RESPONDENTS
No. 32 Bergen Street North Fairview, Quezon City 1100