Republic of the Philippines

DEPARTMENT OF LABOR AND EMPLOYMENT

National Labor Relations Commision
NATIONAL CAPITAL JUDICIAL REGION
Quezon City
-oOo-

RODEL MASUJER MIRANDA,

Complainant,

-versus- NLRC RAB. (L)NCR-09-10517-15

Gets International Development Manpower

Services Incorporated, et al.
Respondents.

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

EX-PARTE MOTION TO RELEASE

MONETARY AWARD AND LEGAL FEES

COMPLAINANT-MOVANT Rodel M. Miranda, through the undersigned counsel

and to this Honorable Commission, respectfully state: That –

1. On August 2, 2019, a Sheriff’s Return was issued as regards this case. The
said Sherriff’s Return, reads in part:

“Pursuant to the ORDER issued by Honorable Labor Arbiter Leah T. Fortuna dated
July 03, 2019 the undersigned was able to collect from Metrobank Trust
Department Branch the total amount of Four Hundred Eighty Four Thousand Six
Hundred Twenty Two Pesos and 58/100 (Php. 484,622.58) representing the full
satisfaction of complainant's monetary award and legal fees, Attached hereto is the
deposit slip bearing OP No. 2019-07-080247 for reference.

In view of the foregoing, having no further reason to proceed with the execution,
the writ is hereby returned FULLY SATISFIED”

2. Considering that this case had long been DECIDED with finality in favor of
the herein Complainant-Movant and what remains as regards this case is the
satisfaction of the monetary judgment, Complainant-Movant respectfully request that
an order be issued for the release of the abovementioned monetary award to him.
 PRAYER

WHEREFORE, in view of the foregoing, it is respectfully prayed that an order be

issued by this Honorable Commission for the release of the total amount of Four
Hundred Eighty Four Thousand Six Hundred Twenty Two Pesos and 58/100 (Php.
484,622.58) representing the full satisfaction of complainant's monetary award and
legal fees with deposit slip bearing OP No. 2019-07-080247 for reference, and, hence,
without need of further hearing.

Makati City for Quezon City, August 12, 2019.

ATTY. REMEGIO C. DAYANDAYAN, JR.

Counsel for Complainant
3rdflr. Universal Re: bldg.
Paseo De Roxas Makati.
Tel. Nos. 813-5238/892-3052 to 58
PTR No. 6623889/01.10.2018 Makati
IBP No.019581/12.28.2017 Quezon City
Roll of Attorney’s No. 55149
5th Compliance No. 0010757; September 25, 2015

NOTICE

Hon. Leah T. Fortuna

Labor Arbiter
Thus Office

GREETINGS:

Please take notice that the undersigned counsel will submit as she
hereby submits the foregoing motion for the consideration and approval of
this Honorable Labor Arbiter immediately upon receipt hereof.

REMEGIO C. DAYANDAYAN, JR.