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Motion To Release Appeal Bond Sample Template
Motion To Release Appeal Bond Sample Template
Motion To Release Appeal Bond Sample Template
Complainant,
-versus-
,
Respondents.
Backwages P 223,400.00
Overtime Pay 506,250.00
Service incentive leave pay 7,500.00
13th month pay 30,000.00
Separation pay 160,000.00
Less- (70,000.00)
Total = P 857,150.00
SO ORDERED.
2. In connection with the perfection of its 9 June 2012 Appeal, the Company, in compliance with
law, posted as cash bond Cashier’s Check No. 0450013745 in the amount of Eight Hundred Fifty-
Seven Thousand One Hundred Fifty Pesos (P 857,150.00) issued by Metropolitan Bank & Trust
Company [ A copy of the Company’s Manifestation is attached as Annex “2”, Motion].
3. On 31 January 2013, the National Labor Relations Commission [the “NLRC”] rendered a Decision
modifying the LA’s Decision, the dispositive portion of which reads:
4. Complainant filed his Motion for Reconsideration and was denied by the NLRC on 15 March
2013.
5. On 13 April 2013, an Entry of Judgment was issued by the NLRC stating that the above-quoted
31 January 2013 Decision became final and executory on 13 April 2013. A copy of the Entry of
Judgment is attached as Annex “4”, Motion.
6. In view of the foregoing, respondents respectfully move that the cash bond posted in the
amount of Seven Hundred Eighty Thousand Fifty-one Pesos & 89/100 (P 780,051.89) be ordered
released.
PRAYER
WHEREFORE, it is respectfully prayed that the foregoing Motion be granted and the cash bond in
the amount of Seven Hundred Eighty Thousand Fifty-one Pesos & 89/100 (P 780,051.89) posted by the
Company be ordered released.
MARTINEZ - NIEVERA
Counsel for Respondents-Appellants
xxxxx
By:
ALBERT M. ARTINEZ
PTR No. xxxxx; xx-xx-xx; Rizal
IBP No. xxxxxx; xx-xx-xx; RSM
Roll No. xxxxx
Admitted to the Bar: xxxxxx
MCLE Compliance: N.A.
COPY FURNISHED:
xxxx
EXPLANATION
xxxx