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Republic of the Philippines

Department of Labor and Employment


NATIONAL LABOR RELATIONS COMMISSION
National Capital Region
Quezon City

xxxxxxxxxxxxxxxxxxxx,
Complainants,

- versus - NLRC NCR Case No. xxxxxxxxxxxxxx

xxxxxxxxxxxxxxxxxx
Respondents.
x------------------------------------------------------x

JOINT MOTION
TO TERMINATE PROCEEDINGS

NOW COME the complainant xxxxxxxxxxxxxxxx, by himself, and the

respondents, by their undersigned counsel, unto this Honorable Office, respectfully

move for the termination of the proceedings in the instant case by virtue of the

settlement between the parties and of the Release, Waiver and Quitclaim executed by the

complainant on the 14th day of August 2012.

A copy of the Release, Waiver and Quitclaim executed by complainant

xxxxxxxxxxxxxxxxx is attached hereto, and made an integral part hereof, as Annex A.

PRAYER

WHEREFORE, it is respectfully prayed that this Honorable Office issue an order

dismissing the complaint with prejudice.

The complainant and the respondents likewise pray for such other measures of

relief as this Honorable Office may deem just and proper under the premises.
Quezon City, 14th day of August, 2012.

xxxxxxxxxxx
xxxxxxxxx

By:

xxxxxxxxxx
Roll No. xxxxxxx
IBP No. xxxxxxxxxxx, xxxxxxxx, xxxx Chapter
PTR No. xxxxxxx, xxxxxxxxx, xxxxxxCity
MCLE Compliance No. xxxxxxxx

xxxxxx
Complainant

NOTICE OF HEARING

THE LABOR ARBITRATION ASSOCIATE


Department of Labor and Employment
National Labor Relations Commission
National Capital Region
Quezon City

GREETINGS:

Due to the non-litigious nature of the foregoing Joint Motion, kindly submit the
foregoing motion for the consideration of this Honorable Office immediately upon your
receipt hereof.

xxxxxxxxx
xxxxxxxxxxxxxx
By:

xxxxxxxxxx
Roll No. xxxxxxx
IBP No. xxxxxxxxxxx, xxxxxxxx, xxxx Chapter
PTR No. xxxxxxx, xxxxxxxxx, xxxxxxCity
MCLE Compliance No. xxxxxxxx

REYNANTE ABALOS
Complainant

ATTY. JAMIL V. ESTORNINOS


Roll No. 57885
IBP No. 889260, 17 February 2012, Occ. Mdo. Chapter
PTR No. 6377148B, 17 February 2012, Quezon City
MCLE Exemption until 2013

ATTY. JAIME R. TEJERO III


Counsel for Respondents
Roll No. 60125
IBP No. 893315, 12 March 2012, Northern Samar Chapter
PTR No. 1059227, 26 March 2012, Muntinlupa City
MCLE Exemption until 2015

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