Republic of the Philippines

Department of Labor and Employment

National Labor Relations Commission
Regional Arbitration Branch,CAR
Magsaysay Avenue, Baguio City

ABIGAIL T. ESMAYA
NABIL S. JAVIER
Complainants

NLRC case no. RAB-CAR09-

0465-15
NLRC CASE no. RAB-CAR-09
0466-15
-versus

THOUGHT
FOCUS TECHNOLOGY, LLC
3RD FLOOR SM CITY, BAGUIO
Respondent
_____________________________________________________________

MOTION TO RELEASE CASH BOND

COMES NOW, the Complainant Nabil S. Javier by and

through the undersigned counsel and unto this Honorable Court
most respectfully states that;

1. During the pre – execution conference on February 4, 2020, it

was agreed by the parties that the monetary award in favor of
the complainant in the amount of EIGHTY-TWO THOUSAND
THREE TEN AND 50/100 PESOS (PHP 82,310.50) and
attorney’s fee in the amount of EIGHT THOUSAND TWO
HUNDRED THIRTY ONE AND TEN CENTAVOS (PHP
8,231.10) shall release thru the cash bond previously posted by
the respondent in relation to this case.

2. The monetary award is stated in the Resolution of the National

Labor Relation Commission dated August 31, 2016 which was
affirmed by the Decision of Court Appeals on September 12,
2018.
 Copies of the Resolution and the Decision of the Court of
Appeals are hereto attached and marked as Annex “A” and Annex
“B”.

3. Previously in this case, Abigail Esmaya received the monetary

award thru the cash bond posted by the respondent based on
the same Resolution of the National Labor Relation dated
August 31, 2016.

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed unto this Honorable Office to release the monetary award in
the amount of EIGHTY-TWO THOUSAND THREE TEN AND
50/100 PESOS (PHP 82,310.50) as award judgment and EIGHT
THOUSAND TWO HUNDRED THIRTY ONE AND TEN
CENTAVOS (PHP 8,231.10) attorney’s fee, through the cash bond
posted by the respondent in this case.

Other reliefs and remedies just and equitable under the

premises are also prayed for.

Done this 4th day of February 2020 at Baguio City Philippines.

MARIA ELENA CARIÑO-TOTANES

For Complainant Nabil S. Javier
Rm. 305, 3/F, Lopez Building D, Session Road, Baguio City
PTR No. 5521143, 01-04-2018, Baguio City
Mem No.1083748, 12-08-2017-2018, Baguio City
MCLE V-0022461 06-14-2016
Roll No. 55020
Tel No. (074) 4248010
 NOTICE AND COPY FURNISHED

NLRC
Regional Arbitration Branch
CAR

Greetings!

Please submit the foregoing Motion for the immediate

consideration of the Honorable Office upon receipt of the same.

Done this 4th day of February 2020 in Baguio City.

MARIA ELENA CARIÑO-TOTANES

Atty Hilario V. Belmes

Counsel of the Respondent
Unit 3H West Burnham Place
16 Kisad Rd., 2600 Baguio City

EXPLANATION

Service of this pleading is done through registered mail due to

distance and lack of personnel.

MARIA ELENA CARIÑO-TOTANES