REPUBLIC OF THE PHILIPPINES

COURT OF APPEALS
MANILA

NINTH DIVISION

__________,
Petitioner,

- versus - __________

__________
Respondents.

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

MOTION FOR CONSOLIDATION

Respondent _______________., by counsel, respectfully

states:

1. On udhsdvh, respondentfd sfjrgjhtj, Inc. filed a

Petition for Certiorari dfhegf with this Honorable Court,

seeking to annul and set aside the following challenged

Decision and Resolution of respondent National Labor

Relations Commission in NLRC CA Case No. sdjfbjfgb entitled

“zfjrjbfkjfgkbj”:

a) Decision dated sfhehguht insofar as it

affirms the Labor Arbiter’s assumption of

jurisdiction over the case, finding that zsfhegirt

was illegally dismissed by petitioner, and holding

jewhfergh. liable to jfoejrgj for unpaid

commissions, reimbursement of withholding tax, and

attorney’s fees;
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b) Resolution dated dheuhgu’s Motion for

Partial Reconsideration of the Decision dated jeg

The Petition is presently pending with the Special

Sixth Division of this Honorable Court, docketed as CA –

Gahdehfhreghrei

2. Subsequently, sjjfreg filed the present Petition

for Review dated 29 October 2001 with this Honorable Court,

questioning the same Decision of the NLRC insofar as it

deleted the award of moral and exemplary damages in her

favor. This case is presently pending with the Ninth

Division of this Honorable Court, docketed as CA –

Gwfhehghrcjhes

3. Clearly, these cases involve not only the same

parties but also identical issues principally bearing on

whether or not there exists an employer-employee

relationship between zsfherhgirtigig and diewgit., and

consequently, whether or not the Labor Arbiter and the NLRC

have jurisdiction over the case and to render the Decision

dated 26 April 2001.

4. The pendency of these cases before the different

divisions of this Honorable Court may result in different

resolutions notwithstanding the identity of the issues

involved – an anomalous situation which should be avoided.

Hence, petitioner uweufher Petition for Review dated 29

October 2001 docketed as sfejgier should be consolidated

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with respondent sfbhrig.’s Petition for Certiorari dated 06

September 2001 docketed as wfierighrihgitr

PRAYER

WHEREFORE, uwehguheuh. respectfully prays that the

present Petition for Review dated 29 October 2001 be ordered

consolidated with the Petition for Certiorari dated 06

September 2001 docketed as CA –G.R. No. wfheuhghruherhguver

resently pending with the Special Sixth Division of this

Honorable Court.

Other reliefs as may be deemed just and equitable under

the premises are likewise prayed for.

25 January 2002.

THE NATIONAL LABOR RELATIONS COMMISSION

PPSTA Building, Banawe Street,
Quezon City

EXPLANATION
(Re: Service through Registered Mail)

In compliance with Section 11, Rule 13 of the Rules of

Court, undersigned counsel respectfully manifests that
service of the foregoing Motion for Consolidation is done by
registered mail owing to time and personnel constraints.

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