Scribd
Upload
224 views3 pages

Legal Apology and Motion Submission

This document is an Apology with Motion to Admit Belated Comment filed by a respondent's counsel with the Court of Appeals in Cebu City, Philippines. It apologizes for the late submission of a required comment on a Motion for Reconsideration. It explains that the delay was due to the counsel's heavy workload and commitments exacerbated by the COVID-19 pandemic. It attaches the required Comment as an annex and prays that the court accepts the apology and admits the belated Comment.

Uploaded by

Cyrus Calaya
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
224 views3 pages

Legal Apology and Motion Submission

This document is an Apology with Motion to Admit Belated Comment filed by a respondent's counsel with the Court of Appeals in Cebu City, Philippines. It apologizes for the late submission of a required comment on a Motion for Reconsideration. It explains that the delay was due to the counsel's heavy workload and commitments exacerbated by the COVID-19 pandemic. It attaches the required Comment as an annex and prays that the court accepts the apology and admits the belated Comment.

Uploaded by

Cyrus Calaya
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd

Republic of the Philippines

COURT OF APPEALS
Cebu City

__________ (__th) Division

___________________ CA-GR CEB-SP No. _____


Petitioners
-versus-

National Labor Relations Commission


_____________
Respondents
x- - - - - - - - - - - - - - - - - - -x

APOLOGY WITH MOTION TO ADMIT


BELATED COMMENT
Respondent, by and through counsel, most respectfully states as
follows:

1. On September 8, 2022, undersigned counsel received a copy of


the Order dated March 9, 2022 of this Honorable Court of
Appeals directing the respondent through counsel to file a
comment on the petitioners’ Motion for Reconsideration within
ten (10) days, in-extendible, from notice of said receipt.

2. Hence, this compliance.

3. Firstly, undersigned humbly apologizes to the Honorable Court


of Appeals for his tardy submission of the private respondent’s
Compliance. Such however was due solely to heavy case load
and stocked up cases and other professional commitments of
equal importance which he has to attend to, and which were
adversely affected by the international pandemic. Nonetheless,
he hereby undertakes to be more attentive in his future
appearances and/or dealings with the Honorable Court.

4. Attached hereto is a copy of the required Comment, marked as


Annex “A-Motion” to form an integral part of this Motion.

PRAYER
Wherefore, it is most respectfully prayed of the Honorable Court of
Appeals to accept the apology and admit the foregoing Comment.
General reliefs just and equitable under the premises are likewise
prayed for.

Respectfully submitted.

Cebu City, Philippines. 17th day of September 2022.

Atty. ________________
Counsel for the Respondents-Appellees
_________________________
________________
________________

Notice

The Division Clerk of Court


Court of Appeals
Cebu

Madame/Sir:

Please submit the foregoing pleading immediately upon receipt


hereof for the consideration and approval of the Honorable Court.

Thank you very much. 

Abogado

 Copy furnished:

Atty. ______________
___________________
Don Juan Avila St., Capitol Site
6000 Cebu City

National Labor Relations Commission


5th Floor, DOLE VII Bldg., Cor. Gen. Maxilom
& Gorordo Avenues, 600 Cebu City

EXPLANATION

Copies of the foregoing Manifestation were served upon the other


parties and filed to the Honorable Court of Appeals by registered mail 1
(with return card) due to distance constraint to effect personal service.

Thank you.

1 See hereto attached Affidavit of Service


Atty. Abogado

You might also like