Republic of the Philippines

COURT OF APPEALS
Manila

SIXTH DIVISION

CIRTEK ADVANCED
TECHNOLOGIES AND
SOLUTIONS, INC.
Petitioner,

- versus - CA-G.R. SP NO. 152839

DOMINGO B. BONIFACIO
AND THE NATIONAL
LABOR RELATIONS
COMMISSION,
Respondents.
x------------------
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MOTION FOR LEAVE TO FILE AND ADMIT

ATTACHED REJOINDER

RESPONDENT DOMINGO B. BONIFACIO, (“Mr.

Bonifacio”), through the undersigned counsel, respectfully
state:

1. Respondent Mr. Bonifacio received on January 16,

2018 a Reply (to the Comment on the Petition for
Certiorari) dated January 8, 2018 (“Reply”) filed by
Petitioner.

2. Petitioner’s Reply contains misleading or

erroneous arguments which must be addressed in order to
aid this Honorable Court in appreciating the facts and the
law applicable to the instant case.

3. In view thereof, Mr. Bonifacio respectfully prays

that he be granted leave to file the attached REJOINDER
and that the same be admitted and considered by this
Honorable Court in the resolution of this case.
 PRAYER

WHEREFORE, Respondent DOMINGO B. BONIFACIO

respectfully prays that he be granted leave to file the
attached REJOINDER and that the same be admitted and
duly considered by this Honorable Court in the resolution of
this case.

Respondent respectfully prays for such further or other

relief as may be deemed just or equitable.

Taguig City for Manila City, February 12, 2018.

ATTY. GERARDO ERESE

Counsel for Mr. Domingo Bonifacio
Unit 708, 7th Floor, The Infinity
26th Street, Bonifacio Global City
Taguig, Philippines 1634
Tel: (+632) 553-0701 / 553-0698
Fax: (+632) 553-2654
Email: gferese@gmail.com
PTR No. 6930111; 1/13/17; Makati City
IBP No. 1063851; 1/13/17, Manila IV
Roll No. 39214
MCLE Compliance No. V-0013700; 13 January 2016

Copy Furnished:

The National Labor Relations Commission

PPSTA Building, 245 Banawe St, Quezon City,
1114 Metro Manila

Laguesma Magsalin Consulta & Gastardo

Counsel for Petitioner
Unit 705 Prestige Tower
F. Ortigas Jr. Road
Ortigas Center, 1605 Pasig City

Cirtek Advanced Technologies and Solutions, Inc.

116 East Main Avenue

Phase V Sez Laguna Technopark
Biñan, 4206 Laguna

2
 EXPLANATION

This MOTION FOR LEAVE TO FILE AND ADMIT

ATTACHED REJOINDER was served upon the other parties
via registered mail due to time, distance and manpower
constraints which made personal service not practicable.

ATTY.
GERARDO F. ERESE