Republic of the Philippines

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION
Regional Arbitration Branch No XX
Chui Ave. Wadab City
-oOo-

XXXXXXXXXXXXXXXXXX NLRC RAB-XX-XXXXX-X

Complainant

-vs- FOR: ILLEGAL DISMISSAL with

MONEY CLAIMS

XXXXXXXXXXXXXXXXX
Respondents
x----------------------------------------------x

MOTION TO REVIVE THE CASE and ADMIT POSITION

PAPER

COMES NOW, the Complainant XXXXXXXXXXXXXXXXXXX with the

assistance of the XXXXXXXXXXXXXXX, unto this Honorable Quasi-judicial
Body, most respectfully avers:

1. That the Complainant belatedly filed a Position Paper on XX March 2019

before this Honorable Body. The latter date is based on the Order dated
XX February 2019 giving the Complainant to file a Position Paper for
Ten (10) days from receipt thereof. The said Order however, was
unsigned by the Labor Arbiter XXXXXXXXXXXX. The Complainant
was then asked by the lawyer handling the case to have the same verified
for signature since this representation submits that an unsigned Order is
just a mere scrap of paper. Attached hereto is a photocopy of the Order
dated XX February 2019 as Annex “A”;

2. That pursuant to an Order of this Honorable Quasi-judicial Body dated

XX March 2019, this case was ordered DISMISSED WITHOUT
PREJUDICE to refiling the same. The case was dismissed for the parties’
non-compliance to the Order for the submission of verified position
papers undersigned on XX February 2019;

3. That the Complainant is pleading before this Honorable Body to

REVIVE and to ADMIT the Position Paper by the Complainant since the
initial Order requiring the Complainant to file a position paper was
unsigned;

4. Henceforth, the Complainant is asking that the Rules of this Honorable

Body be interpreted and applied in his favor to protect his interest as a
laborer.

WHEREFORE, it is most respectfully prayed that the Complainant in this

particular case be allowed to submit his position paper despite of lapse of time
given to him and; that the said motion be dutifully submitted immediately for the
consideration and resolution of this Honorable Court.
 4 April 2019, Wadab City, Davao del Norte, Philippines.

NOTICE OF HEARING

HON. XXXXXXXXXXXXXXXXXXXX
Labor Arbiter
National Labor Relations Commission – RAB No. XXX
Wadab City

Ms. XXXXXXXXXXXXXXXXXX
Respondent

Greetings!

Please be informed that I am submitting the foregoing motion immediately

upon receipt hereof without further oral argument and appearance of counsel.

DENNIS C. SAYCO

Copy Furnished:
HON. XXXXXXXXXXXXXXXXXXXX
Labor Arbiter
National Labor Relations Commission – RAB No. XXX
Wadab City

Ms. XXXXXXXXXXXXXXXXXXXXX
Respondent
Brgy. XXXXXXXXXX
Wadab City