Republic of the Philippines

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION
Quezon City

(EMPLOYER X/EMPLOYEE X)
Appellant-Respondent.

- versus - NLRC CASE NO. _________________

(EMPLOYER Y/EMPLOYEE Y)
Appellees-Complainants.

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

APPEAL AND MEMORANDUM OF APPEAL

COME NOW Appellants-respondents, by counsel, unto this Honorable Commission, most
respectfully state, thus:

JURISDICTIONAL FACTS

1. On (date), appellant-respondent received a copy, through its authorized representative

Mr. X, of the subject Decision of the Hon. Labor Arbiter X in NLRC Case No. XX-XX-
XXXXX-XX entitled (Appellees-complainants) and (Appellant-respondent) Inc.;

2. Thus, appellant-respondent has until (appeal period) within which to file its Appeal and
Memorandum of Appeal;

3. Appellant-respondent most respectfully appeals the Decision of the Hon. (labor arbiter) to
the Honorable Commission and submit the instant Memorandum of Appeal.

4. In his Decision, the Hon. (labor arbiter) ruled, to wit (dispositive portion):

“WHEREFORE, premises considered, judgment is hereby rendered declaring

complainants' dismissal as illegal.”

5. (ground/s for appeal) …. would cause grave or irreparable damage or injury to the
appellant-respondent as discussed in the Assignment of Errors and Arguments below:

ASSIGNMENT OF ERRORS

6. (ground/s for appeal) in the findings of facts in finding that:

a. Complainants-appellees were illegally dismissed.

b. Complainants are entitled to (reliefs)

ARGUMENTS

Complainants-appellees were illegally dismissed.

7.

(rationale for the entitlement to relief/s.

PRAYER:
WHEREFORE, based on the foregoing, it is most respectfully prayed that the ruling of the
Hon. Carpio:

a.

Furthermore, the Complaint by complainants-appellees should be dismissed for being without

any factual or legal basis.

All other relief just and equitable under the premises are likewise prayed for.

XXX City.

(date filed).

ATTY. X
Counsel for Petitioner