Republic of the Philippines Department of Labor and Employment BFO Building, Ortigas Ave cor ED!

A "andaluyong #ity "A!$ER E%&'%EER'%& !ER('#E!, )LL, #omplainant*s + versus+ POEA #A!E %O DA)+,-+,-+.,/0

DO%%ABELLE & LLA&A! Respondent 1++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++1 2O'%$ DE#'!'O% 'n #ivil #ases %os ,,+.34.+" and ,,+.35.+", plaintiffs Ariston, Rey 6enneth, Earl and 2oshua 'van, all surnamed 'nocencio, and Eufronio, "ar7 Andre8, 6ay99in and %i77i, all surnamed :mali, see7 damages from defendants Bicol #argo ;auler 'nc <Bicol #argo for brevity= ;onesto Del (alle, #onrado " Robles and Emilioano Robles for the incident 8hich happened on !eptember .,, 3,,, at around >?>0 o@cloc7 in the afternoon involving an 'su9u ten+8heeler truc7 8ith Plate %o E(;+05. o8ned by defendant Bicol #argo and driven by defendant Del (alle and the passenger Aeepney 8ith Plate %o D!PB43. o8ned by defendant Emiliano Robles and driven by defendant #onrado Robles and 8hich incident 8as particularly described under paragraphs >,0,4 and 5 of plaintiffs@ #omplaints*s as follo8s? > On !eptember .,, 3,,,, at about >?>0 o@cloc7 in the afternoon said 'su9u $en )heeler $ruc7 8ith Plate %o E(;+05., coming from the direction of Famy, Laguna driven by defendant ;onesto Del (alle, in utter disregard of traffic rulers and regulations, 8as traveling at high speed along the %ational ;igh8ay at Barangay %anguma, "abitac, but upon reaching the brige near the crossing, the right front 8heel of said truc7 hit the crossing, the right front 8heel of said truc7 hit the concrete gutter of the briged, causing the trcu7 to s8erve to then entering the left lane of the national high8ay, coming from the provincial road from the direction of !iniloan, LagunaC 0 As a result of the impact, the passenger Aitney 8as thro8n to its left, s7irted and landed on the property on the left side of the national high8ay several meters a8ay from the point of collision as sho8n in the police s7ecth prepared by Police Officer Francisco L &arcia, and because of said collision the said Aitney

became a total 8rec7 resulting to the death of seven <5= passengers of said Aitney, and causing physical inAuries to thirteen <./= passengers aside from said inAuries and damage to the Aitney, said ten 8heeler hauler tru7 hit and damaged the Barngay hall and another 8arehause 1eroD copy of the police s7etch by Police Officer Francisco L &arcia is hereto attached as AnneD EAE of this #omplaintC 4 After conducting an investigation of the incident, !r Police Office Francisco l garcia filed a criminal complaint against the defendant ;onesto Del (alle, for Rec7less 'mprudence Resulting $o "ultiple ;omicide, "ultiple Physical 'nAuries and Damage $o Property 8ith the "unicipal #ircuit $rial #ourt of "abitac, Laguna, doc7eted as #rim #ase %o /33. 1eroD copy of the said criminal complaint dated !eptember ./, 3,,, is hereto attached as AnneD EBE of this #omplaintC 5 Although, the defendant Aitney driver #onrado robles 8as not included as accused in said criminal complaint said defendant 8as li7e8ise guilty of rec7less negligence and violation of traffic rules and regulations in operating saaid passenger Aitney at the time of the accident as he did not ma7e a full stop before entering he national high8ay, coming from the provincial road, and thus his vehicle 8as already at the left lane of the national high8ay slo8ly moving 8hen it 8as bumped and hit by the ten 8heeler truc7C as stated in the police report hereto attached as AnneD E#E ;ad the defendant driver of said passenger Aeepney made a full stop before entering the national high8ay, it may not have been hit and bumped by the 8ay8ard ten 8heeler truc7 E )ith the plaintiffs*defendants Emiliano and #onrado Robles li7e8ise maintaining a case for a damages in #ivil #ase %o ,,+.353+" against defendants Bicol #argo ;auler, 'nc represented by its President, &eorge Pimentel, and ;onesto Del (alle, as follo8s? E3 $hat on !eptember .,, 3,,, at about >?>0 o@cloc7 in the afternoon, SECOND MOTION FOR EXTENSION OF TIME $he respondent, through the undersigned counsel, unto this ;onorable Office, most respectfully avers?
.

$hat the undersigned counsel first motion for eDtension prayed that they be given up to October >, 3,,- 8ithin 8hich to file the verified ans8er

;o8ever, the undersigned counsel still 8aiting for the !pecial Po8er of Attorney for the mother of the respondent and other documents from !ingapore to prepare said verified ans8er

$hat the undersigned 8ould need an additional time to intelligently prepare the said verified ans8er in this case

>

$hat this motion is not intended for delay

);EREFORE, in vie8 of the forgoing, it is respectfully prayed of the ;onorable Philippines Overseas Employment Administration that the respondent be granted an eDtension of fifteen <.0= days from October >, 3,,- 8ithin 8hich to file her ans8er October /, 3,,- !anta #ru9, Laguna

LEO%ARDO " RA&AFA 2R #ounsel for the respondent P$R %o 4-0,>33 * ,.+.-+,'BP Rec %o 53.4-> * ,3+,>+,Attorney@s Roll %o /-/.0 !anta #ru9, Laguna %O$'#E OF !:B"'!!'O% $he Philippines Overseas Employment Administration BFO Building, Ortigas Ave cor ED!A "andaluyong #ity &reetings? 'n vie8 of the non+litigous nature of the foregoing motion, 7indly

submit the same for your consideration immediately upon receipt hereof

LEO%ARDO " RA&AFA 2R