REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF LABOR AND EMPLOYMENT

NATIONAL LABOR RELATIONS COMMISSION
QUEZON CITY

MARLYN MOLINA CASTRO,

Complainant,

- versus - NLRC-CA NO. 033349-02

NLRC-NCR CASE NO. 30-04-01819-02

PRIMER GROUP OF COMPANIES and/or

JIMMY THAI,
Respondents,
x------------------------------------------------------x

MOTION FOR COMPUTATION

AND FOR ISSUANCE OF A
WRIT OF EXECUTION

Complainant MARLYN MOLINA CASTRO, through the undersigned

counsel and unto this Honorable Court, most respectfully states that:

1. On 1 December 2005, the First Division of the Honorable Supreme

Court issued an Entry of Judgment declaring the Resolution dated 8
August 2005 issued in the above-captioned case has become final and
executory. A copy of the said Entry of Judgment is attached hereto as
Annex “A”.

2. Thus, the issuance of a writ of execution is proper in order to enforce

the said Resolution.

3. Prior to the issuance of such writ of execution, a computation on the

backwages and other monetary award should likewise be made in
order to reflect the appropriate amount that should be received by the
complainant.

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Office that a computation on the backwages and other monetary
award be made and thereafter, a Writ of Execution be issued.

Other relief and remedies just and equitable under the premises are
likewise prayed for.

Manila, 27 January 2005.

Department of Justice
PUBLIC ATTORNEY’S OFFICE
Manila District Office
4th Floor William Godino Building,
350 Arroceros Street, Ermita, Manila

By:

ANNE GERALDINE T. AGAR

Public Attorney II
 NOTICE OF HEARING

Mr. JIMMY THAI

Respondent

Greetings:

Please take notice that the foregoing Motion will be submitted for the kind
consideration and approval of the Honorable Office on 2 July 2004 at 8:30AM.

ANNE GERALDINE T. AGAR

Cc.

Mr. JIMMY THAI Reg. Receipt No. _______

Respondent Date: ________
C/o Primer Group of Companies Place: ________
Suite 902 State Centre
No. 333 Juan Luna Street,
Binondo, Manila

exec-castro/anne-f

REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF LABOR AND EMPLOYMENT
 NATIONAL LABOR RELATIONS COMMISSION
QUEZON CITY

MARLYN MOLINA CASTRO,

Complainant,

- versus - NLRC-CA NO. 033349-02

NLRC-NCR CASE NO. 30-04-01819-02

PRIMER GROUP OF COMPANIES and/or

JIMMY THAI,
Respondents,
x------------------------------------------------------x

MOTION FOR RE-COMPUTATION

AND FOR ISSUANCE OF
WRIT OF EXECUTION

Complainant MARLYN MOLINA CASTRO, through the undersigned

counsel and unto this Honorable Court, most respectfully states that:

1. On ____ 2005, the Second Division of the Supreme Court issued an

Entry of Judgment declaring that the Resolution dated 28 April 2004
issued in the above-captioned case has become final and executory on
_______. A copy of the said Entry of Judgment is attached hereto as
Annex “A”.

2. Thus, the issuance of a writ of execution is proper in order to enforce

the said Resolution dated 28 April 2004.

3. Prior to the issuance of such writ of execution, a re-computation on the

monetary award should likewise be made in order to reflect the
appropriate amount that should be received by the complainant.

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Office that a re-computation on the monetary award be made and
thereafter, a Writ of Execution be issued.

Other relief and remedies just and equitable under the premises are
likewise prayed for.

Manila, _____ 2005.

Department of Justice
PUBLIC ATTORNEY’S OFFICE
Manila District Office
th
4 Floor William Godino Building,
350 Arroceros Street, Ermita, Manila

By:

ANNE GERALDINE T. AGAR

Public Attorney II

NOTICE OF HEARING
Atty. Joan P. Serrano
Counsel for Respondents
c/o ROQUE & BUTUYAN LAW OFFICES
Unit 1904, Antel 2000 Corporate Centre
121 Valero Street, Salcedo Village,
1200 Makati City

Greetings:

Please take notice that the foregoing Motion will be submitted for the kind
consideration and approval of the Honorable Office on ____ at 8:30AM.

ANNE GERALDINE T. AGAR

Cc.

Atty. Joan P. Serrano Reg. Receipt No. _______

Counsel for Respondents Date: ________
c/o ROQUE & BUTUYAN LAW OFFICES Place: ________
Unit 1904, Antel 2000 Corporate Centre
121 Valero Street, Salcedo Village,
1200 Makati City

exec-castro/anne-l