motion for execution-labor

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Republic of the PhilippinesDepartment of Labor and EmploymentNATIONAL LABOR RELATIONS COMMISSIONRegional Arbitration Branch No. XIDavao City

AAAA Complainant,

- versus - NLRC CASE NO. RAB-XI-JJJ

BBBBDefendant.x-------------------------------------------x

MOTION FOR EXECUTION OF JUDGMENT

COMES NOW, the Complainant through undersigned counsel and to this Honorable Commission respectfully alleged:

1. That judgment was rendered by this Honorable Commission in favor of theComplainant on __________; 2. That said judgment was duly received by the Defendant on ____________ as shown in the registry return card;3. That up to the present, the defendant had not filed any motion for reconsideration or had appealed from said decision, hence the decision has become final and executory.

WHEREFORE, it is respectfully prayed that an order be issued by this Honorable Commission for a writ of execution for said judgment.

Davao City, Philippines, ______________

Atty. XXXX Counsel for Complainant

NOTICE OF HEARING

THE LABOR ARBITERRegional Arbitration Branch No. XIDavao City

ATTY. GGGGCounsel for the Defendant Greetings! Please take notice that the undersigned counsel willsubmitthe foregoing Motion for Execution to the Honorable Court on _________________ at _____ in the morning for its favorable consideration and approval.

Atty. XXXX Copy furnished byregisteredmail:

ATTY. DDDDCounsel for the Defendant

EXPLANATION

Due to lack of messengerial services to effect personal service, a copy of the foregoing motion was sent to defendant's counsel throughregisteredmail.