REPUBLIC OF THE PHILIPPINES

NATIONAL LABOR RELATIONS COMMISSION

Regional Arbitration Branch No. VII
Cebu City

AAAAAAAAAAAAA,
Complainant,

-versus- NLRC RAB CASE NO. 1111111

BBBBBBBBBBBBBBB,
Respondent/s.
x---------------------------------------/

JOINT MOTION FOR APPROVAL OF

COMPROMISE AGREEMENT

PARTIES, as assisted by their respective counsels, unto this

Honorable Office, most respectfully states as follows:

I. That they have come to an amicable settlement and have executed

a compromise agreement with the following terms and conditions
as follows:

This Agreement is entered into this __ March 2019 at Cebu City,

Philippines by and between:

AAAAAAAAAAAAA, Filipino, of legal age, single with address

at Purok II Fatima Tinaan, City of Naga, hereinafter referred to
as the “Complainant”.
-and-

BBBBBBBBBBBBBBB, a domestic corporation duly organized

and existing under the laws of the Republic of the Philippines
with principal address at Brgy. San Pedro, Morong, Rizal and
represented herein by XXXXXXXXXXXXXX, hereinafter referred
to as the “Respondent”; (Complainant and Respondent are
collectively referred to as the “Parties”)

Agrees follows:

1. The Parties to this compromise agreement hereby voluntarily and

freely express their desire to settle the above-captioned case
peacefully and amicably to their mutual and common advantage.

2. The Respondent agrees to pay the Complainant, by way of financial

assistance in the amount of FIFTY Thousand Pesos (Php.50, 000.00)
which shall be paid as follows:

i. First Payment upon the execution of this compromise

agreement in the amount of Php.25,000.00;
ii. Second Payment on __ March 2019 in the amount of
Php.25,000.00.
 3. The Respondent will reinstate the herein complainant and he will be
included among the project employees who will work for their
project/s in Dipolog City, Zamboanga del Norte by the end of this
month, March 2019. The parties will execute a project employment
contract in connection thereof.

4. This agreement shall not in any way be construed as an admission on

the part of any party of any fault, negligence or liability, of whatever
kind and nature, in connection with the above-captioned case.

5. This Compromise Agreement is not contrary to law, morals, good

customs, public policies and public order.

IN WITNESS WHEREOF, parties herein affixed their signatures on __

March 2019 in Cebu City, Philippines.

AAAAAAAAAAAAAA
Complainant

BBBBBBBBBBBBBBBBBBBB
Represented by XXXXXXXXXXXX
Respondent

Assisted by counsels:

___________________________ ____________________________
Complainant’s Counsel Respondent’s Counsel

II. That they agree that the approval of this agreement by this
Honorable Office shall put an end to this litigation, except for
purposes of execution in case of default.

III. In this regard, parties respectfully move that the said Compromise
Agreement be approved by this Honorable Office.

PRAYER

WHEREFORE, premises considered, parties jointly pray of this

Honorable Office to prove the Compromise Agreement and Order be issued
approving the same.

Other reliefs, just and equitable are likewise prayed for.

Respectfully submitted this __ March 2019 at Cebu City, Philippines.