Republic of the Philippines

Department of Labor and employment

NATIONAL LABOR RELATIONS COMMISSION
Regional Sub-Arbitration Branch VI
Iloilo City

ARTURO P. CALSAS
Complainant,

-versus-

INTERCONTINENTAL BROADCASTING
CORP./ ROBERTO DEL ROSARIO,
PRESIDENT/CEO AND CORA PANIEGO-ROBLES,
STATION MANAGER,
Respondents.
x---------------------------------------------------------x

MOTION FOR THE ISSUANCE OF THE WRIT OF EXECUTION

COMES NOW Complainant, by counsel, and to this Honorable Arbitration

Office, most respectfully moves for the issuance of a writ of execution for the
Decision of the Court of Appeals dated 10 October 2013, considering the
following circumstances:

1. The said decision has already become final and executory on 25

October 2013, fifteen (15) days from the promulgation;

2. The fallo of said decision reads:

WHEREFORE, premises considered, the petition is
PARTIALLY GRANTED. The assailed June 28, 2010
Decision of the National Labor Relations Commission
(NLRC) is MODIFIED in that Private Respondent Arturo
Calsas is declared NOT CONSTRUCTIVELY DISMISSED.
The petitioner International Broadcasting Corporation
however is ordered to pay private respondent the
following:
1. Unpaid Salaries - 61,100.00
th
2. 13 Month Pay - 14,146.91
3. Service Incentive Leave Pay - 2,587.32
TOTAL -77,834.230
4. 10% Attorneys Fees - 7,783.423
GRAND TOTAL -85,617.653
SO ORDERED

3. That Article 224 of the Labor Code provides that a writ of execution
may be issued for the final decisions, orders or awards and a writ may
be issued motu proprio or on motion of any interested party within five
(5) years from the date it becomes final and executory, hence the
issuance of the writ of execution is now in order.
 4. That for the guidance of the honorable office the following Annexes
are herein attached:

ANNEX DECISION
A 22 December 2009 Decision of the Labor Arbiter
Miriam Libron-Barroso (Special Task Force), Iloilo
City
B 28 June 2010 Decision of the National Labor
Relations Commission (NLRC) Seventh Division,
Cebu City
C 10 October 2013 Decision of the Court of Appeals,
Special Eighteenth Division, Cebu City

WHEREFORE, premises considered, it is respectfully prayed that a writ of

execution of the Decision dated 10 October 2013 be issued.

Iloilo City, August __, 2017.