Republic of the Philippines

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION
REGIONAL ARBITRATION BRANCH NO. XI
Davao City

NORMAN LAWAS MATUGAS,

Complainant,

- versus – NLRC Case No. RABXI-02-00021-24

B-MIRK MULTIPURPOSE COOPERATIVE

and JOSHUA NORIEGA-HRMD HEAD/
FRANKLIN BAKER COMPANY OF THE
PHILIPPINES AND ITS PRESIDENT
Respondents,

x-------------------------------------x

MOTION FOR EXTENSION

RESPONDENT, B-MIRK MULTIPURPOSE COOPERATIVE,
through the undersigned and unto this Honorable Court, most
respectfully states:

1. On March 12, 2024, herein respondent received a copy

of the Order date March 12, 2024, to which requiring
herein respondent to file its Verified Position Paper
within Fifteen (15) days from notice/receipt thereof.

2. Herein respondent has until March 27, 2024 within

which to file its Verified Position Paper.

3. However, due to equally important and essential

commitments that entails the performance of
professional work, which consists among others, the
study and preparation of pleadings as well as other legal
documents that includes relevant issues in the instant
case that must be properly addressed, herein respondent
through the undersigned shall require additional period
of time to file its Position Paper.

4. In view of the foregoing, herein respondent is

constrained to beg for the benevolent indulgence and
 understanding of the Honorable Arbitration Branch to
ask for an extension of Ten (10) days from March 27,
2024 to April 08, 2024 to within which to file our
Position Paper.

5. The filing of this motion is not intended for delay but is

necessitated by the foregoing reasons.

RELIEF

Wherefore, it is respectfully prayed of this Honorable Court

that herein respondent be given an additional period of Ten (10)
days from March 27, 2024, or until April 08, 2024 to file its
Verified Position Paper.

Other reliefs just and equitable under the premises are

respectfully prayed for.

Antipolo City for Davao City, March 27, 2024.

RAMON A. CASTRO
Representative of Respondents
No. 9 Pizarro St. Vista Verde Executive Village
Antipolo City

COPY FURNISHED

ATTY. Nenita C. Mahinay

Counsel for the complainants
No. 57- A, Cordillera Street
Corner N. Roxas Street Brgy. Lourdes,
Quezon City

COCA-COLA BEVERAGES PHILS, INC.

Co-Respondent
25th Floor Six Neo Bldg. 5th Avenue Corner
26th Bonifacio, Global City 1635
NATIONAL LABOR RELATIONS COMMISSION
Ben-Lor Building, 1184 Quezon Avenue
Quezon City

EXPLANATION

The filing and or service of the foregoing is/are via registered

mail/alternative courier due to lack of manpower to effect
personal filing and/or service and due to the effect personal
filing and/or service and due to the distance involved and/or
constraints.

RAMON A. CASTRO