Republic of the Philippines

NATIONAL LABOR RELATIONS COMMISSION

Regional Arbitration Branch No. IV
Barangay Halang, Calamba City
MARIO L. TORTILLA,
Complainant,
NLRC RAB IV CASE No. 01-2705-13
-versusCALAMBA TRUCKING SERVICES,
Respondent.
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ENTRY OF APPEARANCE
WITH URGENT OMNIBUS MOTION
COMES NOW, the respondent, through the undersigned counsel, unto
this Honorable Office, most respectfully avers:
1. That respondent engaged the services of the undersigned counsel
where he may be served with the notices and other processes of
this Honorable Office at 112 Panay Avenue, Quezon City;
2. That respondent, with all honesty and good faith, has failed to
appear on the scheduled mandatory conferences set on November
4 and 10, 2014 having no knowledge thereof since Mr. Doy
Duable, respondents liaison officer, who received the summons of
this Honorable Office failed to forward the same to the Human
Resources Department;
3. That respondent happens to know of the mandatory conferences
only on November 13, 2014 when it actually received the Order
(dated November 10, 2014) of the Honorable Labor Arbiter
terminating the mandatory conference and directed the
complainant to submit his Position Paper while the respondent is
deemed to have waived its right to submit the same;
4. That considering the circumstances above-mentioned and to afford
respondent the procedural stages in the settlement of the case
particularly the conduct of mandatory conference for the
possibility of amicably settling the case upon a fair compromise
and to promote labor peace, respondent most respectfully moved
for the reconsideration of the order dated November 10, 2014 and
request to set the case for one last time another
preliminary/mandatory conference, or at the very least respondent
be allowed to submit their position paper to afford them the right to
present their side including evidences relative to this case;

5. That this motion is filed in good faith and with no intention to

delay the proceedings of this Honorable Office but solely on the
above-mentioned reasons.
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed
unto this Honorable Office for the reconsideration of the Order dated
November 10, 2014 to set case for one last time another
preliminary/mandatory conference and/or respondent be allowed to submit
position paper.
Respectfully submitted.
Quezon City (for Calamba City), Philippines, November 18, 2014.
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Roll No. __________
IBP NO. 950183 at Cebu City
PTR NO. 5450591 issued on 01.14.14 at Mandaue City
MCLE Compliance No. III-0010066(Date of issue April 19, 2010)
MCLE Compliance No. IV-0020178 (Date of issue April 23, 2013)
112 Panay Avenue, Quezon City
REQUEST
The Clerk of the Honorable Arbitration Branch
RAB VII
Greetings!
Kindly submit the foregoing motion and position paper for the consideration
of the Honorable Labor Arbiter immediately upon receipt hereof. Thank you.
_____________________

Copy furnished:
Mario L. Tortilla
Pallucan East, Batangas City

Registry Receipt No.

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Date
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Post Office
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