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Comment: (To The Complainant-Appellant'S Motion For Reconsideration)

The document is a "Comment" submitted by the respondent-appellees' counsel in response to the complainant-appellant's "Motion for Reconsideration" of a case ruling. It argues that (1) the complainant failed to raise substantial issues to warrant changing the ruling, merely rehashing previous arguments; and (2) the motion does not identify any errors in the ruling's findings or conclusions under the law. Therefore, the motion should be dismissed and the initial decision upheld in full.

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Sanchez Roman Victor
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440 views2 pages

Comment: (To The Complainant-Appellant'S Motion For Reconsideration)

The document is a "Comment" submitted by the respondent-appellees' counsel in response to the complainant-appellant's "Motion for Reconsideration" of a case ruling. It argues that (1) the complainant failed to raise substantial issues to warrant changing the ruling, merely rehashing previous arguments; and (2) the motion does not identify any errors in the ruling's findings or conclusions under the law. Therefore, the motion should be dismissed and the initial decision upheld in full.

Uploaded by

Sanchez Roman Victor
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF LABOR AND EMPLOYMENT


NATIONAL LABOR RELATIONS COMMISSION
NATIONAL CAPITAL REGION
QUEZON CITY

FIFTH DIVISION

ELORDE MONTANO ADIER,


Complainant-Appellant,

NLRC LAC NO.: 07-002355-18


- versus - NLRC-NCR CASE NO. 14-05815-18
(HON. MONA LISA M. VARGAS)

CTP CONSTRUCTION MINING


CORP. / CARLO PIMENTEL,
Respondent-Appellees.
x------------------------------------------------x

COMMENT
(TO THE COMPLAINANT-APPELLANT’S MOTION
FOR RECONSIDERATION)

RESPONDENTS-APPELLEES, by counsel, unto this


Honorable Commission, respectfully submit this “Comment” to the
complainant-appellant’s “Motion for Reconsideration” to the above-
entitled case, in support thereof aver that:

1. The hard reality is that complainant-appellant failed to raise


matters substantially plausible or compellingly persuasive to
warrant the desired course of action. Complainant-appellant’s
motion for reconsideration was a mere rehash of what their
previous arguments and merits of the case was judiciously passed
upon by the Honorable Labor Arbiter and this Honorable
Commission as evidenced by the assailed Decisions.

2. Considering that the grounds presently raised have been


sufficiently considered, if not squarely addressed, in the subject
Decision, it behooves complainant-appellant to convince the Court
that certain findings or conclusions in the Decision are contrary to
law. As it is, however, the instant motion does not raise any new or

1
substantial legitimate ground or reason to justify the reconsideration
sought. This warrants the outright dismissal of the instant case.

PRAYER

IN VIEW OF THE FOREGOING, it is respectfully prayed that


the instant Memorandum of Appeal be DISMISSED accordingly,
and that the Decision dated January 19, 2020, by the Honorable
Labor Arbiter Mona Lisa M. Vargas be upheld, in toto.

Other reliefs, just and equitable under the premises, are


likewise most respectfully prayed for.

Muntinlupa City for Quezon City, 02 December 2020.

FLORES TALENS ROMANILLOS LAW OFFICES


Counsel for the Respondents
Suite 506 South Center Tower
2206 Market Street Madrigal Business Park,
Ayala Alabang, Muntinlupa City

By:

FELIX J. FLORES III


Counsel for the Respondent-Appellees
Roll of Attorney No. 47255
IBP No. 105576 – 01/09/20 – PPLM
PTR No. 2220666– 01/07/20 – Parañaque City
MCLE Compliance No. VI – 0019548 – valid
until April 14, 2022

Copy Furnished:

ATTY. SISENANDO R. VILLALUZ, JR.


Counsel for the Complainant-Appellant
ELORDE M. ADIER
VILLALUZ &DUQUE LAW OFFICE
9 Azucena Drive, Beverly Hills Subdivision,
Taytay, 1920 Rizal

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