Republic of the Philippines

DEPARTMENT OF LABOR AND EMPLOYMENT

Regional Office 2
Regional Government Center
Carig Sur, Tuguegarao City

IN RE: ROUTINE INSPECTION CONDUCTED LSCN.RO200-1811-RI-0012-ISA

AT ARORA MERCHANDISING,
Bantug, Roxas, Isabela

ARORA MERCHANDISING and/or MR. PRAXEDES

D. ARORA, Owner/Manager
Respondent/s.
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MOTION FOR CLARIFICATORY HEARING

RESPONDENT, thru the, undersigned counsel, unto this Honorable

Office of the Regional Director of the Department of Labor and Employment,
Regional Office 2, most respectfully aver and state among others;

1. Respondent sought the assistance of the undersigned law office

relative the above-captioned inspection/ investigation of which
resulted to a “NOTICE OF COMPLIANCE ORDER” including attached
“ORDER” relative the findings of the Inspector; issued against her
(respondent);

2. With all due respect your honours, while the presumption of

regularity in the performance of a regular function is highly
presumptive, the prevailing circumstances after the conduct of
inspection as regards to the alleged commission and/or omission of
herein respondent may give light to a reasonable and rather just
findings;

3. We likewise adhere to the fact that she (respondent) may have been
given ample time to refute, rebut or to contradict such findings at the
time prior to the issuance of the resolution on the findings of the
inspector and that we submit to this Honorable Office. However, in
light of the foregoing, respondent full heartedly believes that she has
done what is best for her employees under her ward and care;

4. It is of no moment that herein respondent, thru the undersigned,

humbly seeks the indulgence of your honours for the conduct a
CLARIFICATORY HEARING, if so merits the case, for herein
 respondent to be able to explain her side relative said
inspection/investigation and as have been mentioned, merits the
attention of this Honorable Office, respondent be given a moment to
shed light to prove compliance to the requirements laid down by law;

5. Herein respondent, thru the undersigned manifests good faith on the

foregoing lapses, findings against her and in the interest of justice
now seeks for a CLARIFICATORY HEARING on the matter.

WHEREFORE, premises considered, it is most respectfully prayed for

that RESPONDENT, thru counsel be allowed to present COMPLIANCE and/or
controverting pieces of documentary and testimonial evidence to her accord

OTHER just and equitable reliefs are likewise prayed for under the
foregoing premises.
Tuguegarao City, Cagayan; January 2020.

Brillantes & Supnet Law Office

2nd Floor DIWA Building, College Avenue
Tuguegarao City, Cagayan
Counsel for the Respondent

By:

ATTY. NICHOLO RUDOLF A. SUPNET

Roll No. 54755
PTR No. TUG 2743147/01-06-20/Tuguegarao City, Cagayan
IBP Lifetime No. 856429/01-11-13/Tuguegarao City, Cagayan
MCLE Complied, No Certificate issued yet

To: Clerk of Office

Please submit the foregoing to the sound discretion of the

Honorable Regional Director.

Thank You

ATTY. NICHOLO RUDOLF A. SUPNET