REPUBLIC OF THE PHILIPPINES

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION
National Capital Region
Quezon City
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REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH
CITY
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OROSA KAHAYON LAGDAMEO LAW OFFICES
Counsel for Defendant
Room 305 Erlag Building,
102 Esteban Street, Legaspi Village
Makati City
(02) 551-4431
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MIGUEL LUIS H. OROSA
Roll of Attorneys No. 39212
PTR No. 5326855MD/January 6, 2016/ Makati City
IBP NO. 1023542/ January 8, 2016/ RSM
MCLE Compliance No. V-0014357/ February 1, 2016/ Pasig City
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ATTY. MARCO M. LAGDAMEO
Roll of Attorneys No. 41768
PTR No. 5326854MD/ January 6, 2016/ Makati City
IBP LR No. 09506/ January 7, 2011/ Makati City
MCLE Compliance No. V-0007100/ April 1, 2015/ Pasig City
(02) 551-4431
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MICHAEL ALBERT H. KAHAYON
Roll of Attorneys No. 40012
PTR No. 5326853/ January 6, 2016/ Makati City
IBP LR No. 05564/ December 21, 2015/ Makati City
MCLE Compliance No. V-07999/ May 27, 2015/ Pasig City
(02) 551-4431
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I, , Filipino citizen, of legal age, married/single with office address at City
after having been sworn in accordance with law, hereby states:
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PRAYER

WHEREFORE, in view of the foregoing, it most respectfully prayed of this Honorab

le Court that the Motion for the Issuance of a Certificate of Finality be grante
d and consequently, an order be issued for the release thereof.
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PRAYER
WHEREFORE, premises considered, it is respectfully prayed that this Hono
rable Court DISMISS the Complaint for absolute lack of merit and to award in fav
or of Mr. Ricardo:
1.

Moral damages in the amount of Fifty Thousand Pesos ( 50,000.00).

2.
Attorneys Fees in the amount of at least Twenty Thousand Pesos ( 20,000.00
), or in the amount as may be proven in the course of the trial of this case.
3.

Payment or reimbursement of the cost of suit.

Other just and equitable reliefs are also prayed for.

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EXPLANATION
The foregoing COMPLIANCE was served upon the Honorable City Prosecutor assigned
to the Honorable Regional Trial Court of Taguig City, Branch 74, and upon counse
l for the ACCUSED by registered mail and not personally due to limitations of ti
me and lack of messengerial personnel.

MIGUEL LUIS H. OROSA

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EXPLANATION
(Pursuant to Sec. 11, Rule 13 of the 1997 Rules of Civil Procedure)
Copies of the foregoing Comment/Opposition (to Motion to Admit Attached Complain
t and Pre-trial Brief [Third Amendment]) were served upon the parties by registe
red mail, personal service not being practicable due to distance, traffic situat
ion, and time constraints.

MIGUEL LUIS H. OROSA

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