Republic of the Philippines

DEPARTMENT OF LABOR & EMPLOYMENT

NATIONAL LABOR RELATIONS COMMISSION
Regional Arbitration Branch 10
Cagayan de Oro City
Tel. (088) 857.2672/ 0905.413.3173
Email: jjwagarab10@gmail.com

JOPHA H. DOBLE & NLRC CASE NO. RAB(BUK)-10-

DINDO I. DOBLE, 10-00087-2021
Complainants,

-versus-

E.C. MABAO CORPORATION,

NEIL E. CABALLERO &
CLEOFE A. MABAO,
Respondents.
X_______________/

URGENT MOTION FOR ANOTHER EXTENSION

TO FILE POSITION PAPER

RESPONDENTS, by counsel, unto this Honorable Commission,

most respectfully allege that:

1. On 18 January 2022, the respondents through the undersigned

counsel moved for an extension up to February 02, 2022 to submit a
VERIFIED POSITION PAPER

2. Unfortunately, the undersigned was further exposed more

closely to his wife who is a Department of Health (DOH) Nurse who last
January 29, 2022 proved positive of the COVID-19 virus, for which reason
he must spend further time on self-quarantine, as he still has symptoms of
scratchy throat and runny nose;

3. The undersigned would therefore need more time in order to

interview witnesses and gather pieces of evidences in Valencia City to
intelligently prepare the required Verified Position Paper.

WHEREFORE, premises considered, it is most respectfully prayed

that the Respondents be given an additional Five (5) days within which to
submit their Verified Position Paper on or before February 07, 2022.

This motion is not meant to delay the proceedings but is rendered

compelling by the foregoing circumstances.
 Other relief in equity are likewise prayed for.

Cagayan de Oro City, 02 February 2022.

ROBN LAW
Counsel for the Respondents
Ground Floor, Lim Building,
Vamenta Boulevard, Carmen
Cagayan de Oro City
+63 (88) 850 1668
By:

Roll of Attorneys No. 38022, 5.06.92

IBP O.R. No. 183281 (1.03.2022) Bukidnon
PTR O.R. No. 4620979 (1.03.2022) Bukidnon
MCLE Compliance No. VI-0003936 (11.03.17)
Email: asolegario@robnlaw.com
CP 09172465110

NOTICE

THE LABOR ARBITRATION ASSOCIATE

NLRC RAB-10 ( LA J.M. WAGA)
Cagayan de Oro City

GREETINGS!

Please take note/submit the foregoing Motion for the

consideration and approval of the Honorable Commission
immediately upon receipt hereof. Thank you very much.

Copy furnished: PRIVATE COURIER

DINDO and JOPHA DOBLE

Purok 9, Bagontaas, Valencia City