Republic of the Philippines
Department of Labor and Employment
NATIONAL LABOR RELATIONS COMMISSION
Regional Arbitration Branch No. ___
____________ City
(NAME OF HON. LABOR ARBITER)
NAME OF COMPLAINANT/S,
Complainant,
NLRC CASE NO. RAB ________
-versus-
NAME OF RESPONDENT/S,
Respondent.
x-----------------------------------------/
MOTION TO SET CASE FOR MANDATORY CONCILIATION AND MEDIATION CONFERENCE
Respondent, through the undersigned counsel, and unto this Honorable Commission, most respectfully states – THAT:
1. Respondent received the Summons dated (Date) notifying them that a Complaint has been filed against them for alleged illegal dismissal, claiming for separation pay, 13th month pay, and service incentive leave;
2. Pursuant to En Banc Resolution No. 03-20 (Series of 2020), this Motion is hereby submitted to request for mandatory conciliation and mediation conference for possible settlement;
3. Respondent is open to the possibility of compromise. As for the proposed terms and conditions, we respectfully manifest the company’s willingness to give the 13th month pay and monetary equivalent of unused service incentive leave to the complainant;
4. Respondent is ready to attend the conference through in-court session or through video-conferencing or other electronic means.
WHEREFORE, premises considered, respondent respectfully moves that a mandatory conciliation and mediation conference be scheduled for this case.
Other measures of relief, just and equitable under the premises are also prayed for.
______________ City, (Date).
LAWYER DETAILS
Copy furnished:
NAME OF COMPLAINANT
Address of Complainant