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Ex-Parte Motion To Order Release - NLRC Cashier Partial-1

1) The heirs of Eduardo V. Balcita Jr. filed a motion requesting the release of PHP 3,201,804 from funds garnished and collected by the sheriff from the respondents and deposited at the NLRC cashier. 2) This amount constitutes partial satisfaction of the judgment award in favor of the complainants. 3) The motion requests that an order be issued to the NLRC cashier to release the funds to Aileen V. Balcita or her designated representative.

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Manny Sandicho
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473 views

Ex-Parte Motion To Order Release - NLRC Cashier Partial-1

1) The heirs of Eduardo V. Balcita Jr. filed a motion requesting the release of PHP 3,201,804 from funds garnished and collected by the sheriff from the respondents and deposited at the NLRC cashier. 2) This amount constitutes partial satisfaction of the judgment award in favor of the complainants. 3) The motion requests that an order be issued to the NLRC cashier to release the funds to Aileen V. Balcita or her designated representative.

Uploaded by

Manny Sandicho
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

Department of Labor and Employment


NATIONAL LABOR RELATIONS COMMISSION
NCR Regional Arbitration Branch - Quezon City

OFW-SEA BASED
HEIRS OF THE DECEASED NLRC OFW CASE No. NCR-03-03002-14
EDUARDO V. BALCITA, JR., Hon. Labor Arb. EDUARDO J. CARPIO
(Represented by his wife
AILEEN V. BALCITA),
Complainants,

-versus-
TRI-OCEANIC MANNING &
SHIPPING, INC., ET. AL.,
Respondents,
x--------------------------------------x
(FOR PARTIAL SATISFACTION OF JUDGMENT AWARD) PAGE 1 OF 3 - EX-PARTE MOTION TO ORDER RELEASE FUNDS AT THE NLRC CASHIER

EX-PARTE MOTION TO ORDER


RELEASE OF GARNISHED FUNDS
DEPOSITED AT THE NLRC
CASHIER, Ad. Cautelam
(FOR PARTIAL SATISFACTION OF JUDGMENT)

COMPLAINANTS by counsel, respectfully state, that –

The Honorable Sheriff Russel S. Perez garnished and


collected the funds of respondents coming from, inter alia,
the Surety Bond Account at the Pioneer Insurance and
Surety Corporation which delivered a BDO Check in the
amount of THREE MILLION TWO HUNDRED ONE THOUSAND
EIGHT HUNDRED FORTY PESOS (PHP3,201,840.00) constituting
a “partial satisfaction” of the judgment award.

The remainder of the judgment award inclusive of the


10% Attorney’s Fees, plus Execution and Deposit Fees will
come from respondents’ funds at the Philippine National
Bank (PNB) which was likewise ordered by this Honorable
Office to be released by way of an Order dated 27 July 2015.
Copy of Sheriff’s Report dated 10 August 2015 is
hereto attached for immediate reference.

RELIEF
WHEREFORE, it is respectfully asked of this Honorable
Office that an ORDER TO RELEASE be issued to the NLRC
CASHIER to RELEASE the above-stated amount of
PHP3,201,804.00 in favor of complainants through Aileen V.
Balcita or her designated representative in partial
satisfaction of the judgment award.

Other reliefs just and equitable are likewise


respectfully sought.

Santa Cruz, Laguna and Quezon City, 11 August 2015.


(FOR PARTIAL SATISFACTION OF JUDGMENT AWARD) PAGE 2 OF 3 - EX-PARTE MOTION TO ORDER RELEASE FUNDS AT THE NLRC CASHIER

Atty. EMMANUEL E. SANDICHO


Legal Counsel for Complainants
CSWAP, Room 402-B Web-Jet Building
64 Quezon Ave. cor. BMA Ave., Quezon City
E-mail address: [email protected]
IBP O.R. No. 971375, 05 January 2015, Laguna
PTR O.R. No. 2545478, 05 January 2015, Laguna
Roll No. 42246 admitted to practice, 09.05.1997
MCLE Compliance No. IV-0021894 / 04.09.2013

NOTICE OF SUBMISSION

THE LABOR ARBITRATION ASSOCIATE


OFFICE OF HON. L.A. EDUARDO J. CARPIO
3/F Bookman Bldg., Quezon Ave.,
Quezon City

Please take notice that undersigned will submit the


foregoing motion for the consideration and approval by the
Hon. Labor Arbiter Eduardo J. Carpio upon receipt hereof.

Atty. EMMANUEL E. SANDICHO


Legal Counsel for Complainants
(FOR PARTIAL SATISFACTION OF JUDGMENT AWARD) PAGE 3 OF 3 - EX-PARTE MOTION TO ORDER RELEASE FUNDS AT THE NLRC CASHIER
ANNEX “A”

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