Republic of the Philippines

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION
Regional Arbitration Branch No. VI
Iloilo City

Bryan Moore A. De la Cruz et. al, (and

71 Others)
Complainants
-versus- NLRC SRAB CASE NO VI-08-50246-2017
NLRC Case No. VAC-03-000191-2018
Hon. Labor Arbiter Rodrigo P. Camacho
HACIENDA ASUNCION, HACIENDA
MARINA/ JORGE VARGAS (OWNER)
AND ROLEEN ERAGA (Employer’s
Representative)
Respondents.

EX PARTE MOTION FOR ISSUANCE OF A WRIT OF

EXECUTION

COMES NOW COMPLAINANTS, through the undersigned and to this

Honorable Office most respectfully alleges and manifests that:

1. On 7 June 2018, the undersigned received a Notice of Decision

dated 28 May 2018 with the attached Decision dated 24 May 2018
(Annex “A”) from the Honorable Seventh Division of the National
Labor Relations Commission-Cebu City which favorably decided in
favor of the herein Complainants to wit:

“WHEREFORE, premises considered, the Labor

Arbiter’s 30 January 2018 Decision is hereby modified as
follows:
1. The monetary awards granted to Jovanie
Cantanilla are CANCELLED; and
2. The moral and exemplary damages awarded to
complainants are likewise CANCELLED, reducing their
monetary awards to One Million Two Hundred Thirty-One
Thousand Eight Hundred Eighty Eight & 62/100
(P1,231,888.62) Pesos, representing their salaries/wages and
ten percent (10%) attorney’s fees. ”

2. On 18 August 2018, the undersigned received a Notice of

Resolution dated 27 July 2018 with the Resolution dated 26 July
2018 (Annex “B”) from the same Honorable Commission denying
the Motion for Reconsideration of the herein Respondents for lack of
merit and reiterating in toto the above-mentioned Decision;

1
 3. Finally, the undersigned has come into the knowledge that that
the Original Records of this case has been transmitted back to
NLRC Sub-arbitration Branch VI-Iloilo City on 19 December
2018;

4. Thus, it is respectfully moved that a Writ of Execution be

issued in favor of the Complainants.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed

that the Manifestations be noted and the instant Motion be granted.

All such other reliefs just and equitable are likewise prayed for.

Respectfully submitted.

Iloilo City, Philippines. 20 December 2018.

ATTY. MARY LOUISE S.VILLEGAS

COUNSEL FOR THE COMPLAINANTS
DUREMDES NAVA VILLEGAS
2nd Floor, A & L Bldg. ,E. Lopez St., Jaro, Iloilo City
IBP No. 1049089 -Iloilo City-Dec 11, 2017
PTR No. 5812133-Iloilo City- January 5, 2018
Roll of Attorney’s No. 65334
MCLE Compliance No. VI-0010209 valid until 14 April 2022

THE CLERK OF COURT

For: Hon. Rodrigo P. Camacho
NLRC SRAB VI-ILOILO CITY
Iloilo City

Please submit the foregoing Motion for the consideration of this Honorable Office
without need of any further oral arguments.

Atty. Mary Louise S. Villegas