Republic of the Philippines

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION
Regional Arbitration Branch No. I
2/F GSMA Bldg. Gov. Ortega, Gen. Luna St.
San Fernando City, La Union

ARNOLD S. ANDRADA
Complainant-Appellee,

- versus - NLRC CASE NO. RAB-1-04-1078-17

(SFLU)
NLRC LAC NO. 10 - 003730 - 18

THUNDERBIRD PILIPINAS,
RESORT & HOTEL, INC. and/or
DAVID LAWRENCE,
Respondent-Appellant.

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

COMPLIANCE AND MOTION FOR EXECUTION OF

FINAL ORDER/JUDGMENT

COMES NOW, the Complainant through undersigned counsel and to

this Honorable Commission respectfully alleged:

1. That pursuant to the order of the NLRC RAB 1 through Labor

Arbitration Associate Knoli A. Macadangdang, herein complainant-
appellee through counsel respectfully submits the Court of Appeals’
decisions dated and promulgated March 6, 2019 (Annex A) and June
11, 2019 (Annex B) on the petition for review on certiorari by
respondent-appellant on the decision dated and promulgated November
14, 2018, and on their subsequent motion for reconsideration on the
decision of the Honorable Court of Appeals denying their petition for
review on certiorari, respectively;

2. That the foregoing decisions of the Honorable Court of Appeals

dismissed respondent-appellant’s petition for review on certiorari and
its subsequent motion for reconsideration thereof;

3. That for reference of the Honorable NLRC RAB 1 in the final

computation of the money claims and separation pay of herein
complainant-appellee as ordered pursuant to the decision of the
Honorable National Labor Relations Commission, Sixth Division,
 attached herewith are copies of the decisions rendered by the
Honorable Labor Arbiter Catherine Legados-Parado (Annex C), the
subsequent decision it rendered on the appeal made by the respondent-
appellant (Annex D), and certification of the entry of judgment dated
March 11, 2019 (Annex E);

4. That on January 25, 2019 herein complainant-appellee filed a

motion for execution of judgment pursuant to the foregoing decision
and entry of judgment by the Honorable Sixth Division of the National
Labor Relations Commission which to date remains pending;

5. That in view of the foregoing, herein complainant-appellee

REITERATES to the Honorable Commission through the Office of the
Labor Arbiter (NLRC RAB 1) his previous motion for the issuance of a
writ of execution for the said judgment after it has finally computed the
amount for his money claims and separation pay pursuant to the final
decision by the Sixth Division of the NLRC dated November 14, 2018
and entered/recorded in its Book of Entries of Judgment on November
30, 2018.

WHEREFORE, it is respectfully prayed that an order be issued by

this Honorable Commission through the Office of the Labor Arbiter (NLRC
RAB 1) for a writ of execution for said judgment.

San Fernando City, La Union, Philippines, __________________.

MOSUELA, GONZALES AND ASSOCIATES LAW OFFICES

Counsel for Complainant-Appellee
NORTESURLU BLDG., PUROK 3, SEVILLA
SAN FERNANDO CITY, LA UNION

By:

JAIME C. GONZALES, JR.

Roll No. 68552, May 29, 2017
IBP O.R. No. 098528, January 4, 2019 (LU Chapter)
PTR No. LU 3411669A, January 4, 2019
MCLE Comp. No. VI-0007263, valid until April 14, 2022
 NOTICE OF HEARING

THE LABOR ARBITER

Regional Arbitration Branch No. I
San Fernando City, La Union

ATTY. JANICE C. ESPARRAGO-MARGATE

Counsel for Respondent-Appellant

Greetings!

Please take notice that the undersigned counsel will submit the
foregoing Compliance and Motion for Execution for the favorable
consideration and approval of the Honorable Commission through the
Office of the Labor Arbiter (NLRC RAB 1) on August 15, 2019 at 9:00
o’clock in the morning or as soon as counsel and matter may be heard.

JAIME C. GONZALES, JR.

COPY FURNISHED: (via registered mail

with return card)

ATTY. JANICE C. ESPARRAGO-MARGATE

Unit 1503, 15th Floor Taipan Place
F. Ortigas Jr. Road, Ortigas Center
1605 Pasig City

EXPLANATION

Due to lack of messengerial services to effect personal service, a copy of

the foregoing motion was sent to the respondent through counsel
by registered mail with return card.

JAIME C. GONZALES, JR.