Republic of the Philippines

Department of Labor and Employment

NATIONAL LABOR RELATIONS COMMISSION
Regional Arbitration Branch No. 02
Tuguegarao City, Cagayan

Freddie T. Tagapan, NLRC RAB II-08-00227-2017

Complainant,

-versus-

Mega-Matrix Security, Inc.

And/or Engr. Jose R. Simeon and/or
Aderans Philippines, Inc. and/or
The Owner/Manager, General Manager,
President,
Respondents.
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MOTION
(To admit Position Paper of complainant)

COMES NOW, the Complainant through the Public Attorney’s Office by the undersigned counsel,
unto the Honorable Labor Arbiter respectfully pray that:

1. The undersigned prays for the admission of the position paper of the complainants for the
reason that she had to equally attend to voluminous pleadings relevant to her duty as a public
attorney, including court and quasi-judicial body appearances and other services rendered by
her office on a daily basis.

2. Invoking the interest of substantial justice, complainants through the undersigned respectfully
prays that the same be admitted into the records of the case and heard based on its merits;

3. It is for the sole purpose, above stated that the motion is filed and was never intended to delay
the speedy administration of justice.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed that the position paper of

complainants be admitted into the records of the case.

Respectfully submitted.

November 10, 2017. Tuguegarao City, Cagayan.

VANESSA TUMANENG HERRERO

Public Attorney II

CC:
Atty. Razel Anne Felix
CMI Bldg.,315 Commonwealth
Avenue, Q.C.

Aderans Phils.
Lot A-5 Clark Premier,Industrial Park,
M.A. Roxas Highway,Clark Freeport Zone
Clark Field,Pampanga