Republic of the Philippines

NATIONAL LABOR RELATIONS COMMISSION

Regional Arbitration Branch No. VII
Cebu City

ERICKSON M. TALLO
Complainant,

-versus- NLRC RAB-VII-CASE NO. 11-2254-16

KANG CHOK SERVICES, INC./

CROWN REGENCY HOTEL & TOWERS
Respondents,
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MOTION TO ADMIT POSITION PAPER

COMES NOW, Petitioner, through the undersigned counsel, and unto this

Honorable Court most respectfully manifests that on January 26, 2016

representatives from Crown Regency Hotel and Towers went to the NLRC to

check on the status of the case and was surprised to find out that respondent

Crown Regency Hotel and Towers was declared in default for having failed to

attend the mandatory conciliation. Respondent was under the impression that a

counsel represented this respondent and that a lawyer was attending for it

during the hearings. Respondent is therefore constrained to engage the special

entry of the undersigned for this purpose.

In the interest of justice and fair play, it is humbly prayed that respondent

be allowed to present evidence in its defense and that the Motion to admit

Position paper be granted. There is a meritorious, legitimate and justifying

reason for its failure to appear and file its pleadings on time even as the facts will

bear out that there was neither abuse nor illegal reasons for the termination of

the employment of the complainant. In fact, due process was accorded the

complainant as the records will show.

PRAYER
 WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court to ADMIT the Position Paper of respondent Crown Regency

Hotel and Towers.

Other relief and remedies fair and equitable under the premises are

likewise prayed for.

Respectfully submitted this February 6, 2017. Cebu City, Philippines.

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______________________

_______________________

The Honorable Labor Arbiter

NLRC

SIR/MA’AM:

Greetings! Kindly submit the foregoing motion to admit Position Paper to

the Honorable Court on ______________ at 8:30 o’clock in the morning or
immediately upon receipt thereof without further arguments or presence of
counsel. Thank you very much.

__________________

EXPLANATION ON THE MODE OF SERVICE

Due to the distance between the offices of the undersigned counsel and
the following counsels of the parties and the lack of office personnel who could
effect personal service, copies of the foregoing pleading were sent through
registered mail.

_________________________
Copy Furnished:

Erickson Tallo
A. Tumulak St.
Gun-ob, Lapu Lapu City
_____________________
_____________________

Merlinda alvarez
Kang chok Services Inc.
Unit 25 The Atrium
Andres Abellana St.,
Guadalupe, Cebu City
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