Republic of the Philippines

Department of Labor and Employment

National Labor Relations Commission
National Capital Region
Quezon City

LA MA. CLARADEL C. JAVIER-ROTOR

KAYE EDROSOLO MARAMARA and

MARY JOY V. DELA CRUZ,
Complainant,

NLRC Case No. NCR-01-00052-21

-versus-

WAYPOINT SHIPPING & MARITIME SERVICES CORP.,

WILBERT L. REYES and WELSON L. REYES,
Respondents.
X- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -X

COMPROMISE AGREEMENT
This Compromise Agreement entered into this ______________________ in Que-
zon City, Philippines by and between:

KAYE EDROSOLO MARAMARA, of legal age. Single/married, Filipino and herein

assisted by her counsel, Atty. DAMASO D. FALLARME of Manicad Ong & Fal-
larme Law Office, Suite 309, Pelbel Building, 2019 Shaw Boulevard, Pasig City and
hereinafter referred as complainant MARAMARA;

-and-

MARY JOY V. DELA CRUZ, of legal age, single/married Filipino and with postal ad-
dress at ____________________________________________ hereinafter referred to as
complainant DELA CRUZ;

-and-

WAYPOINT SHIPPING & MARITIME SERVICES CORP., WILBERT L.

REYES and WELSON L. REYES, herein after represented by WELSON L. REYES in
his capacity as Crewing Manager, of legal age, married, Filipino and with postal address
at
hereinafter referred to as the Respondent WAYPOINT SHIPPING;

Witnesseth that:
 WHEREAS, Complainants MARAMARA and DELA CRUZ and Respondents
WAYPOINT SHIPPING & MARITIME SERVICES CORP. are the Parties in the
above entitled case pending before this Honorable Office;

WHEREAS, the Parties desire to settle the payment of the monetary award in
the above captioned case between themselves and to that end are willing to enter into
this compromise agreement;

NOW, THEREFORE, in consideration of the foregoing premises, and in full

settlement of their respective claims against each other, the parties have agreed as
follows:

1. The complainants MARAMARA and DELA CRUZ agrees to the settle-

ment of their monetary award on a staggered basis as stated in the scheduled of
payments attached as Annexes “1” and “2” of this Compromise Agreement and
made and integral part hereof;

2. That Respondent WAYPOINT SHIPPING will settle the stated schedule of

payments via postdated checks and shall ensure that the same shall be funded dur-
ing its presentment by the Complainants;

3. For this purpose, complainants MARAMARA and DELA CRUZ and re-
spondent WAYPOINT SHIPPING shall jointly execute a Motion to Lift the No-
tice of Garnishment in relation to the Writ of Execution issued by Hon. LA MA.
CLARADEL C. JAVIER-ROTOR dated 24 February 2022 in order that the re-
spondent WAYPOINT SHIPPING will be able to utilize the funds in their bank
accounts to fund the postdated checks issued to the complainants.

4. The parties understand that this agreement is in settlement of the above-

captioned case, thus, the parties agreed to submit the same to this Honorable Of-
fice so that a judgment may be rendered based on this agreement. In addition, the
parties understand that this agreement supersedes all and any agreement, under-
standing, or arrangement between them prior to this with respect to the above cap-
tioned case.

5. The complainants MARAMARA and DELA CRUZ and respondents

WAYPOINT SHIPPING understand and agree that any violation of the condi-
tions, stipulations, and/or terms herein set forth shall result in this Compromise
Agreement to be automatically canceled without need of notice.

6. It is expressly understood that upon execution of this Compromise

Agreement, the parties hereby waive their respective claims and interests
against each other and the same shall be the full and complete settlement of the
above-mentioned case.

7. The provisions of this agreement shall likewise bind the parties’ respec -
tive assignee, transferee and/or successor-in-interest as the case may be.
 8. The parties understand that if any of the provisions contained in this
Compromise Agreement shall be declared invalid, illegal or unenforceable in
any respect, the validity, legality and enforceability of the remaining provi -
sions hereof shall not in any way be affected or impaired.

IN WITNESS WHEREOF, the parties have hereunto affixed their signatures this
____ day of September 2022 at Quezon City, Philippines.

Complainant KAYE EDROSOLO MARAMARA

Assisted by: Atty. DAMASO D. FALLARME

Complainant JOY V. DELA CRUZ, for herself

Respondent WAYPOINT SHIPPING & MARITIME SERVICES CORP.,

represented by WELSON L. REYES

Assisted by: Atty. GRACE K. EVASCO