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MOTION For EXECUTION Cordova
MOTION For EXECUTION Cordova
The complainant, through the undersigned Public Attorney, to this Honorable Office,
most respectfully moves for the execution of judgment rendered in the above-captioned case
and in support thereof avers that:
1. On October 28, 2022, a decision was rendered by this Honorable Office, the
dispositive part of which is quoted hereunder as follows:
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1. Full backwages from the date he was illegally dismissed until finality of this
Decision tentatively computed as of the date hereof;
2. Separation pay in lieu of reinstatement computed at one (1) month salary for every
year of service, a fraction of six (6) months to be considered as one (1) year from
date of hire until finality of this Decision, tentatively computed as of the date
hereof; and
3. Attorney’s fees equivalent to ten (10%) percent of the total monetary award payable
to the Public Attorney’s Office, pursuant to Section 16-D of R.A. 9406 and Section
35 of its Implementing Rules and Regulations.
2. The Public Attorney’s Office (PAO) received a copy of the aforesaid Decision on
May 8, 2023;
3. No notice of appeal nor any pleading was received by either the complainants or
the undersigned counsel up to this date even as it can be fairly assumed that copies of the
decision were simultaneously released for and received by the parties in this case. Neither did
the respondents pay or take steps to satisfy the award in favor of herein complainants. Thus,
for all intents and purposes, the decision has already become final and executory and the
issuance of a Writ of Execution is thereby warranted.
1
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of this Honorable
Office that a Writ of Execution be issued. Other reliefs, just and equitable, under the premises
are likewise prayed for.
RESPECTFULLY SUBMITTED.
This _____ day of May 2023, at Puerto Princesa City, Palawan, for Calamba City.
GREETINGS:
Please submit the foregoing Motion for Execution to the Honorable Labor Arbiter for
his consideration and approval without further oral arguments.
Thank you.
ATTY. TEODORO JOSE M. BRUNO III
Please take notice that the undersigned counsel is submitting the foregoing Motion for
Execution to the Honorable Labor Arbiter for his consideration and approval without further
oral arguments.
Thank you.
ATTY. TEODORO JOSE M. BRUNO III
CERTIFICATION/EXPLANATION
This is to certify that the foregoing Motion for Execution of Judgment was served to
the respondents by registered mail since personal service and filing is impractical due to
geographic reasons, financial constraints, and lack of sufficient personnel of the PAO.