REPUBLIC OF THE PHILIPPINES

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION
REGIONAL ARBITRATION BRANCH NO. III
City of San Fernando, Pampanga

JEFFREY PAMPLONA,
RICHARD MALTO
PENAJERO,
Petitioners,

- versus – NLRC Case No. RAB III-08-0082-

23

B-MIRK ENTERPRISES
CORPORATION, and DAISY
DIZON, HR,
Respondent
.

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

MOTION FOR EXTENSION

RESPONDENT, B-MIRK Enterprises Corporation, through
the undersigned and unto this Honorable Court, most respectfully
states:

1. On September 5, 2023, herein respondent received a copy of

the Resolution dated August 1, 2023, to which requiring herein
respondent to file Comment and Opposition on the Petition for
Certiorari within Ten (10) days from notice thereof.
2. Herein respondent has until September 15, 2023 within which
to file Comment and Opposition.

3. However, due to equally important and essential commitments

that entails the performance of professional work, which consists
among others, the study and preparation of pleadings as well as
other legal documents that includes relevant issues in the instant
case that must be properly addressed, herein respondent through
the undersigned shall require additional period of time to file its
Comment and Opposition.

4. In view of the foregoing, herein respondent is constrained to

beg for the benevolent indulgence and understanding of the
Honorable Court to ask for an extension of Fifteen (15) days from
September 15, 2023 to September 30, 2023 to file Comment and
Opposition.

5. The filing of this motion is not intended for delay but is

necessitated by the forgoing reasons.

RELIEF

Wherefore, it is respectfully prayed of this Honorable Court

that herein respondent be given an additional period of Fifteen
(15) days from September 15, 2023, or until September 17, 2023
to file Comment and Opposition on the Petition for Certiorari.

Other reliefs just and equitable under the premises are

respectfully prayed for.

Antipolo City for Manila, September 13, 2023.

COPY FURNISHED AND EXPLANATION

ATTY. Nenita C. Mahinay
Counsel for the complainants
No. 57- A, Cordillera Street
Corner N. Roxas Street Brgy. Lourdes,
Quezon City

COCA-COLA BEVERAGES PHILS, INC.

Co-Respondent
25th Floor Six Neo Bldg. 5th Avenue Corner
26th Bonifacio, Global City 1635

NATIONAL LABOR RELATIONS COMMISSION

Ben-Lor Building, 1184 Quezon Avenue
Quezon City

The filing and or service of the foregoing is/are via registered

mail/alternative courier due to lack of manpower to effect
personal filing and/or service and due to the effect personal
filing and/or service and due to the distance involved and/or
constraints.

RAMON A. CASTRO
Representative of Respondents
No. 9 Pizarro St. Vista Verde Executive Village
Antipolo City