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Republic of the Philippines

REGIONAL TRIAL COURT


10th Judicial Region
Branch 26
Medina, Misamis Oriental
-0-

PEOPLE OF THE PHILIPPINES,


Plaintiff, Crim. Case No. 184-M (2017)

-versus- For: RECKLESS IMPRUDENCE


RESULTING IN LESS
SERIOUS PHYSICAL
ALEXANDER MACAMAY y INJURIES
OBEDENCIO,
Accused,

x------------------------------/

URGENT MOTION FOR POSTPONEMENT

Comes now, Atty. Dan Patrick S. Garcia, from Legal Aid


Clinic of the Integrated Bar of the Philippines-Misamis
Oriental Chapter, and unto the Honorable Office most
respectfully submits this urgent motion for postponement, to
wit:

1. That per ORDER dated July 13, 2017, the Integrated


Bar of the Philippines-Misamis Oriental Chapter was
directed by this Honorable Court to represent the
accused in the above-titled case. Thereafter, the
Chairman of the IBP Legal Aid-Misamis Oriental, Atty.
Anna C. Caroz, has referred the case to this
representation in a letter dated August 1, 2017 which,
in return, I have accepted;

2. However, I was told just last Friday that I would be


having a hearing and/or oath taking for the issuance of
new notarial commission before the Honorable
Executive Judge on August 31, 2017. The same date
with the scheduled hearing of the above case;

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3. Due to this predicament, the undersigned could not
possibly appear and represent the above-named
accused on the scheduled hearing. Hence, this motion;

4. That instant motion is filed in good faith and never


intended to delay the proceedings of the Honorable
Court.

WHEREFORE premises considered it is most


respectfully prayed unto the Honorable Court that an
extension of Fifteen (15) days be granted and respondent be
given until August 19, 2017 within which to file Counter-
Affidavit.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, Philippines, for Zamboanga


Sibugay, August 4, 2017.

MERLIN P. CAIÑA & ASSOCIATES


Counsel for the respondent
2/F Consortium Building
Corrales Extension, Cagayan de Oro City
Mobile No. 09268261008
Landline Phone number (088) 880-3822
Email Address: mpc_lawoffice@yahoo.com

SYLVAN GERALD L. SABIO


IBP CDO (O.R. No.) 1059511; Jan. 06, 2017
PTR CDO (O.R. No.)3295855, Jan. 03, 2017
MCLE Compliance No. V–0009408, July 27, 2015
MCLE Compliance No. VI–0000814, Sept.29, 2016
TIN 178-265-979; Roll No. 45542

Notice of Hearing

APP Jeric Salarde Kagaoan


Office of the Provincial Prosecutor
Zamboanga, Sibugay

Harijan Maturan Iklaman

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Greetings!!

The undersigned will submit the foregoing motion for the


resolution and approval of the Honorable Court immediately
upon receipts sans oral arguments with or without the
appearances of parties.

SYLVAN GERALD L. SABIO

Copy furnished by Registered mail:

Harijan Maturan Iklaman


Brgy. Matirling, Ungkaya,
Pukan, Basilan Province

RD.No. ________________ dated _______________;

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Crim. Case No. M17-06-2176

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THE PEOPLE OF THE CRIMINAL CASE NO. M17-06-
PHILIPPINES 2175
Plaintiff,

GINA C. TAN, VIOLATION OF B.P BLG. 22


-------------------
--- /

REPLY-AFFIDAVIT

The examination of GINA C. TAN was conducted and


supervised

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public of the Philippines
REGIONAL TRIAL COURT OF MISAMIS ORIENTAL
10TH Judicial Region
Branch 41
Cagayan de Oro City

THE PEOPLE OF THE CRIMINAL CASE NO. 2014-


PHILIPPINES 104
Plaintiff,

LETY VALENTIN CAGA, et.al.,


-------------------
--- /

MOTION TO RESET HEARING

Undersigned, counsel for accused Daral unto the


Honorable Court most respectfully states, to wit;

The above-entitled case is set for hearing on July 20,


2017 at 8:30 o’clock in the morning. Considering that the
common sur-rebuttal witness to be presented is not free and
available on the above-entitled date, it is most respectfully
prayed that the above scheduled date be cancelled and the
same be reset on November 7, 2017 at 8:30 o’clock in the
morning

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This motion is not intended to delay the proceedings of
the above-entitled case, but for the reason aforesaid. The
public prosecutor has been informed and requested of this
resetting through Cellular Phone call.

Against the foregoing background, it is most


respectfully prayed that the hearing of the above-entitled
case on July 20, 2017at 8:00 o’clock in the morning be
cancelled and the same be reset on November 7, 2017 at
8:30 o’clock in the morning.

Wherefore, it is most respectfully prayed of the


Honorable Court that the hearing scheduled on July 20,
2017 at 8:30 o’clock in the morning be cancelled and the
same be reset to November 7, 2017 at 8:30 o’clock in the
morning.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, Philippines. July 13, 2017.

MERLIN P. CAIÑA & ASSOCIATES


Counsel for the Accused
2/F Consortium Building
Corrales Extension, Cagayan de Oro City

MERLIN P. CAIÑA
IBP (OR) 1059597; Jan. 10, 2017,CDOC
PTR No.3329962; Jan. 5, 2017, CDOC
MCLE Compliance No. V-0000702 10.29.14
TIN NO. 114-722-311 ; Roll No. 24443

NOTICE OF SUBMISSION

TO: THE CLERK OF COURT


REGIONAL TRIAL COURT
Brach 41, Cagayan de Oro City

Greetings!

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Please submit the foregoing MOTION immediately
upon receipt hereof, for the consideration of the Honorable
Court, sans further oral arguments and appearance of the
undersigned counsel

MERLIN P. CAIÑA

Copy furnished by Registered mail:

ATTY. ARNOLD REUBEN L. AGUILAR


Ombudsman Prosecutor II
Office of the Ombudsman for Mindanao
3rd Flr., Herrera Co. Bldg. Inc., Alvares St.,
Sta. Ana, Davao City
RR NO. ________________ dated: ____________;

ATTY. VINCENT CROMWELL V. SEREÑA


RS Bldg., Rosario Limketkai Avenue
Macajalar St., Camaman-an
Cagayan de Oro City
RR NO. ________________ dated: ____________;

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MERLIN P. CAIÑA & ASSOCIATES
Counsel for the Accused
2/F Consorsium Building
Corrale Extension, Cagayan de Oro City

MERLIN P. CAIÑA & ASSOCIATES


Counsel for the Accused
2/F Consorsium Building
Corrale Extension, Cagayan de Oro City

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Republic of the Philippines
REGIONAL TRIAL COURT
10th Judicial Region
Branch 24
Cagayan de Oro City

PEOPLE OF THE PHILIPPINES, CR. ORD. CASE NO. 2016-


Plaintiff, 1156

-versus-

ROSY JANE S. HAWILE


LINAAC,
Accused, FOR: BIGAMY
x- - - - - - - - - - - - - - - - /

MOTION TO WITHDRAW CASH BOND

Accused, by counsel unto the Honorable Court most


respectfully moves to withdraw her Cash Bond put up for her
temporary liberty, in the above-entitled case and alleges,
THAT;

1. For her provisional liberty accused put up a cash


bond in the amount of Php24,000.00 in the form of
Cash Bond as evidenced by Official Receipt No.
3727588 dated March 9, 2017 in her on name (ROSY
JANE H. LINAAC);

2. On 22nd day of March 2017, for having pleaded guilty


to a lesser offense she was sentence to suffer the
penalty of Two (2) Years, Four (4) Months, as
minimum, to Four (4) Years, Two (2) months, as
minimum, all of Pricion Correccional and there was
no civil liability or indemnity on the sentence;

3. It is submitted, there is no legal impediment which


would prevent the release of the subject Cash Bond
above-mentioned.

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WHEREFORE, it is most respectfully prayed of the
Honorable court the Cash Bond put up of the accused as
evidenced by the afore-stated Official Receipt be release or
withdrawn by the accused.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, Philippines, April 25, 2017

MERLIN P. CAIÑA & ASSOCIATES


Counsel for the Accused
2/F Consortium Building
Corrales Extension, Cagayan de Oro City
Mobile No. 09268261008
Landline Phone number (088) 880-3822
Email Address: mpc_lawoffice@yahoo.com

MERLIN P. CAIÑA
IBP (OR) 1059597; Jan. 10, 2017,CDOC
PTR No.3329962; Jan. 5, 2017, CDOC
MCLE Compliance No. V-0000702 10.29.14
TIN NO. 114-722-311 ; Roll No. 24443

Notice of Hearing

HON. CLERK OF COURT


RTC Br. 24,
Cagayan de Oro City

Office of the City Prosecutor

Greetings!!

The undersigned will submit the foregoing motion for the


resolution and approval of the Honorable Court immediately
upon receipts sans oral arguments with or without the
appearance of counsel.

MERLIN P. CAIÑA

13 | P a g e
Copy furnished by Registered mail:

Office of the City Prosecutor


City Hall, Cagayan de Oro City
BY _______________________

MR. DANTE E. ABATO


MRS

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Republic of the Philippines
REGIONAL TRIAL COURT
10th Judicial Region
Branch 11
Manolo Fortich Bukidnon

SPS. RANULFO AND CIVIL CASE NO. 17-01-188


LUZVIMINDA BACABIS, (Formerly 16-532 of the 2nd
Plaintiff, MCTC)

-versus-

HEIRS OF SPOUSES JUAN


AND CONSUELO EMANO, et.
al., FOR: QUIETING TITLE
Defendant ,
x- - - - - - - - - - - - - - - - /

MOTION FOR 2ND EXTENSION OF TIME


TO FILE APPELLANTS BRIEF

Plaintiffs, by counsel unto the Honorable Court most


respectfully states, to wit;

That per ORDER of the Honorable Court dated February


3, 2017 and which was received by the plaintiff on February
15, 2017, Plaintiff is directed to submit Appellants Brief
within Fifteen (15) days from receipt of the said Order.
However, due to the numerous other personal and
professional commitments of the undersigned, frankly
speaking, he cannot possibly file it on time as being prayed
for in the previous motion which is supposed to end on
March 16, 2017.

Due to this predicament the undersigned respectfully


moves for another and last extension of FIVE (5) days from
today within which to file Appellants Brief on or before March
21, 2017.

That instant motion is filed in good faith and never


intended to delay the proceedings of the Honorable Office.

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WHEREFORE premises considered it is most
respectfully prayed unto the Honorable Court that an
extension of Five (5) days be granted and plaintiff be given
until March 21, 2017 within which to file Appellants Brief.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, Philippines, March 16, 2017

JAMES K. JUDITH
Counsel for the Plaintiffs
PTR No. 3346667A Jan. 05, 2017
IBP O.R. No. 1059504 Jan. 06, 2017 Mis. Or Chapter
MCLE Compliance V-0000344, July 31, 2013
Roll No. 46884; May 3, 2002
TIN No. 909-580-546
Mobile Phone No. 09279754361
Landline Phone No. (088) 857-3316
Email address: jameslegal2006@yahoo.com
#186 Hayes cor. Corrales Street
Cagayan de Oro City

Notice of Hearing

HON. CLERK OF COURT


RTC Br. 11,
Manolo Fortich, Bukidnon

Heirs of Spouses Juan and


Consuelo Emano et. al.,

Greetings!!

The undersigned will submit the foregoing motion for the


resolution and approval of the Honorable Court immediately
upon receipts sans oral arguments with or without the
appearances of parties.

JAMES K. JUDITH

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Copy furnished by Registered mail:

VESTINA EMANO-YBAÑEZ
JOVITA EMANO-MERCADO
AVELINA EMANO-ZAPATOS
RAFAEL B. EMANO
SOLEDA EMANO-CORTES
VICENTA B. EMANO
Gusa, Cagayan de Oro City

RD.No. ________________ dated _______________;

REPUBLIC OF THE PHILIPPINES


10TH Judicial Region
REGIONAL TRIAL COURT OF MISAMIS ORIENTAL
BRANCH 24
Cagayan de Oro City

PEOPLE OF THE PHILIPPINES CRIM. CASE NO. 2013-650


Plaintiff

-vs-

ANTONIO PANILAG,
-Accused FOR: FRUSTRATED
- - - - - - - - - - - - - - - - - - / HOMICIDE

URGENT MOTION FOR POSPONEMENT

Accused, by counsel unto the Honorable Court most


respectfully states, to wit;

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That, the above-entitled case is set for hearing on
March 14, 2017 at 8:30 o’clock in the morning. Due to
conflict of schedule as undersigned counsel was previously
committed to appear for hearing in the case of Pp. vs.
Gregorio G. Sabio, before Municipal Circuit Trial Court of
Tagoloan, Misamis Oriental in the morning sessions, as
counsel for Accused he could not possibly attend to the
hearing of the above-entitled case before this Honorable
Court, unless, the same be cancelled and reset to April 12,
2017 at 8:30 o’clock in the morning

This motion is not intended for delay.

WHEREFORE, it is most respectfully prayed of the


Honorable Court that the hearing scheduled on March 14,
2017 at 8:30 o’clock in the morning be cancelled and the
same be reset to April 12, 2017 at 8:30 o’clock in the
morning.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, Philippines. March 13, 2017.

MERLIN P. CAIÑA & ASSOCIATES


Counsel for the Accused
2/F Consortium Building
Corrales Extension, Cagayan de Oro City
Mobile No. 09268261008
Landline Phone number (088) 880-3822
Email Address: mpc_lawoffice@yahoo.com

SYLVAN GERALD L. SABIO


IBP CDO (O.R. No.) 1059511; Jan. 06, 2017
PTR CDO (O.R. No.)3295855, Jan. 03, 2017
MCLE Compliance No. V–0009408, July 27, 2015
MCLE Compliance No. VI–0000814, Sept.29, 2016
TIN 178-265-979; Roll No. 45542

Hon. Clerk of Court

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RTC Br. 24,
Cagayan de Oro City

ACP Labuntog

Kindly, take notice that the above-entitled motion be


submitted to the Honorable Court immediately upon receipt
hereof, sans oral arguments.

SYLVAN GERALD L. SABIO

Copy furnished by personal service:

Assistant City Prosecutor Labuntog


City Hall, Cagayan de Oro City

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Republic of the Philippines
REGIONAL TRIAL COURT
10th Judicial Region
Branch 11
Cagayan de Oro City

SPS. RANULFO AND CIVIL CASE NO. 17-01-188


LUZVIMINDA BACABIS, (Formerly 16-532 of the 2nd
Plaintiff, MCTC)

-versus-

HEIRS OF SPOUSES JUAN


AND CONSUELO EMANO, et.
al., FOR: QUIETING TITLE
Defendant ,
x- - - - - - - - - - - - - - - - /

MOTION FOR EXTENSION


TO FILE APPELLANTS BRIEF

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Plaintiffs, by counsel unto the Honorable Court most
respectfully states, to wit;

That per ORDER of the Honorable Court dated February


3, 2017 and which was received by the plaintiff on February
15, 2017, Plaintiff is directed to submit Appellants Brief
within Fifteen (15) days from receipt of the said Order.
However, due to the heavy legal works and almost daily
appearances on Court, the undersigned counsel cannot
possibly comply with the Order and submit Appellants Brief.
It was only today that the undersigned counsel formally
discussed the matter with the defendant.

Due to this predicament the undersigned respectfully


moves for an extension of FIFTEEN (15) days from today
within which to file Appellants Brief on or before March 16,
2017.

That instant motion is filed in good faith and never


intended to delay the proceedings of the Honorable Office.

WHEREFORE premises considered it is most


respectfully prayed unto this Honorable Court that an
extension of Fifteen (15) days be granted and plaintiff be
given until March 16, 2017 within which to file Appellants
Brief.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, Philippines, March 1, 2017

JAMES K. JUDITH
Counsel for the Plaintiffs
PTR No. 3346667A Jan. 05, 2017
IBP O.R. No. 1059504 Jan. 06, 2017 Mis. Or Chapter
MCLE Compliance V-0000344, July 31, 2013
Roll No. 46884; May 3, 2002
TIN No. 909-580-546
Mobile Phone No. 09279754361
Landline Phone No. (088) 857-3316
Email address: jameslegal2006@yahoo.com
#186 Hayes cor. Corrales Street

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Cagayan de Oro City

Notice of Hearing

HON. CLERK OF COURT


RTC Br. 11,
Manolo Fortich, Bukidno

Heirs of Spouses Juan and


Consuelo Emano et. al.,

Greetings!!

The undersigned will submit the foregoing motion for the


resolution and approval of the Honorable Court immediately
upon receipts sans oral arguments with or without the
appearances of parties.

JAMES K. JUDITH

Copy furnished by Registered mail :

VESTINA EMANO-YBAÑEZ
JOVITA EMANO-MERCADO
AVELINA EMANO-ZAPATOS
RAFAEL B. EMANO
SOLEDA EMANO-CORTES
VICENTA B. EMANO
Gusa, Cagayan de Oro City

RD.No. ________________ dated _______________;

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REPUBLIC OF THE PHILIPPINES
10TH Judicial Region
REGIONAL TRIAL COURT OF MISAMIS ORIENTAL
BRANCH 44
INITAO, MISAMIS ORIENTAL

IN RE: PETITION FOR LRC CASE NO. 2012-1067


REISSUANCE OF THE
DECREE AFTER ITS
CANCELLATION OF DECREE
NO. DECREE NO. 746850,
DATED MAY 5, 1941
PERTAINING TO LOT NO.
11608, B.L. CAD-237, B.L.
CASE NO. 13, CADASTRAL
CASE NO. 26, LRC CAD. REC.
NO. 1591, OF THE
CADASTRAL SURVEY OF
CAGAYAN, PROVINCE OF
MISAMIS ORIENTALAND
DIRECTING THE LAND
REGISTRATION
AUTHORITY TO ISSUE
NEW DECREE OF
REGISTRATION AND
CORRESPONDING

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CERTIFICATE OF TITLE
PER SECTION 39, PD 1529
IN RELATION TO LRA
CIRCULAR NO. 35.

BERNARDINO L. NAGAC,
herein represented by
ADRIAN L. NAGAC,
-petitioner
------------------/

MOTION FOR POSTPONEMENT

Petitioner, by counsel unto the Honorable Court most


respectfully states, to wit;

That, the above-entitled case is set for hearing on


November 21, 2016 at 8:30 o’clock in the morning. Due to
conflict of schedule as undersigned counsel was previously
committed to appear for hearing in the case of, Lordezo
Jardin vs. Victoria Hojas, before Regional Trial Court, Branch
18, Cagayan de Oro City in the morning sessions, as counsel
for defendants he could not possibly attend to the hearing of
the above-entitled case before this Honorable Court, unless,
the same be cancelled and reset to January 20, 2016 at
8:30 o’clock in the morning

This motion is not intended for delay.

WHEREFORE, it is most respectfully prayed of the


Honorable Court that the hearing scheduled on November
21, 2016 at 8:30 o’clock in the morning be cancelled and the
same be reset to January 20, 2016 at 8:30 o’clock in the
morning.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, Philippines. November 18, 2016.

MERLIN P. CAIÑA & ASSOCIATES


Counsel for the accused
2/F Consortium Building
Corrales Extension, Cagayan de Oro City

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Mobile No. 09268261008
Landline Phone number (088) 880-3822
Email Address: mpc_lawoffice@yahoo.com

MERLIN P. CAIÑA
IBP (OR) 1011647; 12.22.2015,CDOC for (2016)
PTR No.3040044; 12.22.2015,CDOC for (2016)
MCLE Compliance No. V- 0000702 10.29.14
TIN NO. 114-722-311 ; Roll No. 24443

SYLVAN GERALD L. SABIO


IBP CDO (O.R. No.) 1011648; Dec. 22, 2015 (for 2016)
PTR CDO (O.R. No.) 3040044, Dec. 22, 2015 (for 2016)
MCLE Compliance No. V–0009408, July 27, 2015
TIN 178-265-979; Roll No. 45542

Hon. Clerk of Court


RTC Br. 44,
Initao, Misamis Oriental

APP Jan J. Parrado

OFFICE OF THE SOLICITOR GENERAL

Land Registration Authority

Kindly, take notice that the above-entitled motion be


submitted to the Honorable Court immediately upon receipt
hereof, sans oral arguments.

SYLVAN GERALD L. SABIO

Copy furnished by Registered mail :

APP Jan J. Parrado Land Registration


Office of the Provincial Authority
Prosecutor Deliman Quezon City
Initao, Misamis Oriental RD No. _____________
RD No. _____________ dated November 18, 2016
dated November 2016

OFFICE OF THE
SOLICITOR GENERAL
134 Amorsolo Street, Legaspi

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Village,
Makati City
RD No. ____________ dated
November 18, 2016

Republic of the Philippines


SUPREME COURT
MUNICIPAL TRIAL COURT IN CITIES
Branch 4
Cagayan de Oro City

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XAVIER TIBOD BANK, INC., CIVIL CASE NO. 116-SEPT-
Plaintiff, 090

-versus-

RONNY V. OBSIOMA FOR: COLLECTION OF SUM


Defendant , OF MONEY
x- - - - - - - - - - - - - - - - /

MOTION FOR EXTENSION TO FILE ANSWER

Defendant, by counsel unto the Honorable Court most


respectfully states, to wit;

That per SUMMONS of the Honorable Court dated


October 6, 2016 and which was received by the defendants
on October 18, 2016, defendant is directed to submit answer
or any responsive pleading within Fifteen (15) days from
receipt of the said Order. However, due to the heavy legal
works and almost daily appearances on Court, the
undersigned counsel cannot possibly comply with the Order
and submit answer and/or any responsive pleading. It was
only today that the undersigned counsel formally discussed
the matter with the defendant.

Due to this predicament the undersigned respectfully


moves for an extension of FIFTEEN (15) days from today
within which to file answer and/or any responsive pleading
on or before November 18, 2016.

That instant motion is filed in good faith and never


intended to delay the proceedings of the Honorable Office.

WHEREFORE premises considered it is most


respectfully prayed unto the Honorable Court that an
extension of Fifteen (15) days be granted and defendant be
given until November 18, 2016 within which to file his
answer and/or any responsive pleading.
Other reliefs and remedies just and equitable under the
premises are likewise prayed for.

29 | P a g e
Cagayan de Oro City, Philippines, November 3, 2016.

MERLIN P. CAIÑA & ASSOCIATES


Counsel for the defendant
2/F Consorsium Building
Corrale Extension, Cagayan de Oro City
Mobile No. 09268261008
Landline Phone number (088) 880-3822
Email Address: mpc_lawoffice@yahoo.com

MERLIN P. CAIÑA
IBP (OR) 1011647; 12.22.2015,CDOC for (2016)
PTR No.3040044; 12.22.2015,CDOC for (2016)
MCLE Compliance No. V- 0000702 10.29.14
TIN NO. 114-722-311 ; Roll No. 24443

SYLVAN GERALD L. SABIO


IBP CDO (O.R. No.) 1011648; Dec. 22, 2015 (for 2016)
PTR CDO (O.R. No.) 3040044, Dec. 22, 2015 (for 2016)
MCLE Compliance No. V–0009408, July 27, 2015

Notice of Hearing

HON. CLERK OF COURT


MTCC,Cagayan de Oro City

ATTY. GEORGINA P. SUMICAD-HUERBANA

Greetings!!

The undersigned will submit the foregoing motion for the


resolution and approval of the Honorable Office immediately
upon receipts sans oral arguments with or without the
appearances of parties.

SYLVAN GERALD L. SABIO

Copy furnished by Registered mail :

ATTY. GEORGINA P.HUERBANA


1000 Dongallo Compound, Hayes Ext.
Camaman-an, Cagayan de Oro City
RR#__________________;

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Republic of the Philippines
DEPARTMENT OF JUSTICE
National Prosecution Service
OFFICE OF THE PROVINCIAL PROSECUTOR
Manolo Fortich, Bukidnon

RUTH MAYORMITA Y NPS DOCKET NO. X-01A-INV-


TAGLINAO 16D-00106
Complainant,

-versus-
FOR: ATTEMPTED RAPE
RICHARD MOLEJON
Respondent,
x- - - - - - - - - - - - - - - - - -
- /

MOTION FOR EXTENSION TO FILE COUNTER


AFFIDAVIT

Respondent, by counsel unto the Honorable Court most


respectfully states, to wit;

That per Order of the Honorable Office dated April 25th


2016 and which was received by the undersigned counsel
on May 13, 2016, respondents is directed to submit their
Counter-Affidavit within Ten (10) days from receipt of the
said Order. However, due to the heavy legal works and
almost daily appearances on Court, the undersigned cannot
possibly comply with the Order and submit today the
Counter-Affidavit. It was only today that the undersigned
counsel formally discuss the matter with the respondent.

Due to this predicament the undersigned respectfully


moves for an extension of TEN (10) days from today within

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which to file her Counter-Affidavit on or before May 23,
2016.

That instant motion is filed in good faith and never


intended to delay the proceedings of the Honorable Office.

WHEREFORE premises considered it is most


respectfully prayed unto the Honorable Court that an
extension of Ten (10) days be granted and respondent be
given until May 23, 2016 within which to file his Counter-
Affidavit.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, (for Manolo Fortich Bukidnon)


Philippines. May 13, 2016.

MERLIN P. CAIÑA & ASSOCIATES


Counsel for the Respondent
2/F Consorsium Building
Corrale Extension, Cagayan de Oro City

MERLIN P. CAIÑA
IBP (OR) 1011647; 12.22.2015,CDOC for (2016)
PTR No.3040044; 12.22.2015,CDOC for (2016)
MCLE Compliance No. V- 0000702 10.29.14
TIN NO. 114-722-311 ; Roll No. 24443

Notice of Hearing

OFFICE OF THE PROVINCIAL PROSECUTOR


Cagayan de Oro City

RUTH T. MAYORITA

33 | P a g e
Greetings!!

The undersigned will submit the foregoing motion for the


resolution and approval of the Honorable Office immediately
upon receipts sans oral arguments with or without the
appearances of parties.

MERLIN P. CAIÑA

Copy furnished by Registered mail :

RUTH T. MAYORITA
Tubod Umagling,
Malitbog, Bukidnon
RR# ____________________:

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Republic of the Philippines
REGIONAL TRIAL COURT OF MISAMIS ORIENTAL
10TH Judicial Region
Branch 41
Cagayan de Oro City

THE PEOPLE OF THE CRIMINAL CASE NO. 2014-


PHILIPPINES 104
Plaintiff,

LETY VALENTIN CAGA, et.al.,

------------------/

MOTION TO RESET HEARING

Undersigned, counsel for accused Daral unto the


Honorable Court most respectfully states, to wit;

The above-entitled case is set for hearing on June 2,


2016 at 8:30 o’clock in the morning. Considering that the
undersigned counsel has already allotted the whole
months of June and July 2016 respectively, to attend
to his personal engagements and/or commitments
equally important with court hearings, his first available
date to have the continuous hearing of the above-entitled
case is on August 4, 2016 at 8:30 o’clock in the morning.

This motion is not intended to delay the proceedings of


the above-entitled case, but for the reason aforesaid.

Against the foregoing background, it is most


respectfully prayed that the hearing of the above-entitled
case on June 2, 2016 at 8:00 o’clock in the morning be

36 | P a g e
cancelled and the same be reset on August 4, 2016 at 8:30
o’clock in the morning.

Wherefore, it is most respectfully prayed of the


Honorable Court that the hearing schedule on June 2, 2016
at 8:30 o’clock in the morning be cancelled and the same be
reset to August 4, 2016 at 8:30 o’clock in the morning.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, Philippines. May 5, 2016 15,


2016.

MERLIN P. CAIÑA & ASSOCIATES


Counsel for the Accused
2/F Consorsium Building
Corrale Extension, Cagayan de Oro City

MERLIN P. CAIÑA
IBP (OR) 1011647; 12.22.2015,CDOC for (2016)
PTR No.3040044; 12.22.2015,CDOC for (2016)
MCLE Compliance No. V- 0000702 10.29.14
TIN NO. 114-722-311 ; Roll No. 24443

NOTICE OF SUBMISSION

TO: THE CLERK OF COURT


REGIONAL TRIAL COURT
Tenth Judicial Region
Brach 41, Cagayan de Oro City

Greetings!

Please submit the foregoing MOTION immediately


upon receipt hereof, for the consideration of the Honorable
Court, sans further oral arguments and appearance of the
undersigned counsel

MERLIN P. CAIÑA

Copy furnished by Registered mail:

37 | P a g e
ATTY. ARNOLD REUBEN L. AGUILAR
Ombudsman Prosecutor II
Office of the Ombudsman for Mindanao
3rd Flr., Herrera Co. Bldg. Inc., Alvares St.,
Sta. Ana, Davao City
RR NO. ________________ dated: ____________;

ATTY. VINCENT CROMWELL V. SEREÑA


RS Bldg., Rosario Limketkai Avenue
Macajalar St., Camaman-an
Cagayan de Oro City
RR NO. ________________ dated: ____________;
ATTY. ARNOLD REUBEN L. AGUILAR
Ombudsman Prosecutor II
Office of the Ombudsman for Mindanao
3rd Flr., Herrera Co. Bldg. Inc., Alvares St.,
Sta. Ana, Davao City

ATTY. VINCENT CROMWELL V. SEREÑA


RS Bldg., Rosario Limketkai Avenue
Macajalar St., Camaman-an
Cagayan de Oro City

MERLIN P. CAIÑA & ASSOCIATES


Counsel for the Accused
2/F Consorsium Building
Corrale Extension, Cagayan de Oro City

MERLIN P. CAIÑA & ASSOCIATES


Counsel for the Accused
2/F Consorsium Building
Corrale Extension, Cagayan de Oro City

38 | P a g e
39 | P a g e
Republic of the Philippines
REGIONAL TRIAL COURT OF MISAMIS ORIENTAL
10TH Judicial Region
Branch 18
Cagayan de Oro City
Maramag Bukidnon

CAPITOL UNIVERSITY CIVIL CASE NO. 007-15-P


MEDICAL CITY FOUNDATION
INCORPORATED HEREIN REP. For: PETITION OR
BY AGUSTINE E. CONSOLIDATION OF
VILLANUEVA, OWNERSHIP OF TRANSFER
Plaintiff, CERTIFICATE OF TITLE NO.
P-406613 UNDER PACTO DE
-versus- RETRO SALE

ESPERIDEON L. BALURAN
SPOUSE
Defendants,
- - - - - - - - - - - - - - - -/

MOTION TO RESET WITH NOTICE OF CHANGE OF


ADDRESS

Plaintiff, by counsel unto the Honorable Court most


respectfully states, to wit;

That, the above-entitled case is set for hearing on


February 10, 2016 at 9:00 o’clock in the morning. Due to
personal commitment on the said date, he could not possibly
attend to the hearing of the above-entitled case before this
Honorable Court, unless, the same be cancelled and reset to
June 16, 2016 at 9:00 o’clock in the morning

That office address of the plaintiffs’ counsel (MERLIN


P. CAIÑA AND ASSOCIATES) has been change, to wit;

OLD ADDRESS: 2/F Ligan Building


#188 Lapasan Highway
Lapasan, Cagayan de Oro City

NEW ADDRESS: 2/F Consortium Building


Corrales Extension
Cagayan de Oro City

40 | P a g e
The undersigned counsel wishes that he be furnish
copies of notices, orders and processes of the Honorable
Court at his new office address.

This motion is not intended for delay.

Wherefore it is most respectfully prayed of the


Honorable Court that the hearing scheduled on February 10,
2016 at 9:00 o’clock in the morning be cancelled and the
same be reset to June 16, 2016 at 9:00 o’clock in the
morning.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, (for Maramag, Bukidnon)


Philippines. February 4, 2016.

MERLIN P. CAIÑA & ASSOCIATES


Counsel for the Plaintiff
2/F Consorsium Building
Corrale Extension, Cagayan de Oro City

SYLVAN GERALD L. SABIO


IBP CDO (O.R. No.) 1011648; Dec. 22, 2015 (for 2016)
PTR CDO (O.R. No.) 3040044, Dec. 22, 2015 (for 2016)
MCLE Compliance No. V–0009408, July 27, 2015
TIN 178-265-979; Roll No. 45542

Hon. Clerk of Court


MCTC Tagoloan-Villanueva
Misamis Oriental

Kindly, take notice that the above-entitled motion be


submitted to the Honorable Court immediately upon receipt t
hereof, sans oral arguments.

SYLVAN GERALD L. SABIO

Copy furnished by Registered mail :

Espiridion Baluran & Spouse


Poblacion, Pangantucan

41 | P a g e
Bukidnon
RR NO. ________________ dated: ____________;

Republic of the Philippines


REGIONAL TRIAL COURT OF MISAMIS ORIENTAL
10TH Judicial Region
Branch 18
Cagayan de Oro City

IN THE MATTER OF SPEC. PROC. CASE NO. R-


VOLUNTARY INSOLVENCY 2013-029
AND LIQUIDATION OF ASSET
OF JONATHAN V. ATON AND
GRACE R. ATON,

JONATHAN V. ATON AND


GRACE ATON,
Petitioners.

- - - - - - - - - - - - - - -/

MOTION TO RESET WITH NOTICE OF CHANGE OF


ADDRESS

Plaintiff, by counsel unto the Honorable Court most


respectfully states, to wit;

1. That the above-entitled case is set for hearing on


February 18, 2016 at 2:00 o’clock in the afternoon. And due
to twist of events wherein undersigned counsel has to attend
other equal important but personal case scheduled on the
same date, he is compelled to request that the above-
entitled case be reset to another date coupled by the fact
that petitioner has to look for another person qualified to be
a substitute liquidator per order of the Honorable Court
dated January 21, 2016.

2. That this motion is not intended for delay but for


reasons herein stated.

3. Against the foregoing background it is most


respectfully prayed that the hearing of the above-entitled
case on February 18, 2016 at 2:00 o’clock in the afternoon
be cancelled and the same be reset on April 14, 2016 at
2:00 o’clock in the afternoon.

42 | P a g e
That office address of the plaintiffs’ counsel (MERLIN
P. CAIÑA AND ASSOCIATES) has been change, to wit;

OLD ADDRESS: 2/F Ligan Building


#188 Lapasan Highway
Lapasan, Cagayan de Oro City

NEW ADDRESS: 2/F Consortium Building


Corrales Extension
Cagayan de Oro City

The undersigned counsel wishes that he be furnish


copies of notices, orders and processes of the Honorable
Court at his new office address.

Wherefore, it is most respectfully prayed of the


Honorable Court that the hearing scheduled on February 18,
2016 at 9:00 o’clock in the morning be cancelled and the
same be reset to April 14, 2016 at 2:00 o’clock in the
afternoon.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, Philippines. February 15, 2016.

MERLIN P. CAIÑA & ASSOCIATES


Counsel for the Plaintiff
2/F Consorsium Building
Corrale Extension, Cagayan de Oro City

MERLIN P. CAIÑA
IBP (OR) 1011647; 12.22.2015,CDOC for (2016)
PTR No.3040044; 12.22.2015,CDOC for (2016)
MCLE Compliance No. V- 0000702 10.29.14
TIN NO. 114-722-311 ; Roll No. 24443

Hon. Clerk of Court


RTC Br. 18
Cagayan de Oro City

ATTY. CRISTINA JUGADOR

43 | P a g e
ATTY. ALEXANDER PAULINO

ATTY. ARTURO PERALTA

Kindly, take notice that the above-entitled motion be


submitted to the Honorable Court immediately upon receipt t
hereof, sans oral arguments.

MERLIN P. CAIÑA

Copy furnished by Registered mail :

ATTY. CRISTINA JUGADOR


Pambato blg., Ramon Chaves
Cagayan de Oro City RR# ___________ dated
_____________:

ATTY. ALEXANDER PAULINO


c/o Planters Bank
Cagayan de Oro Branch
Cagayan de Oro City RR# ____________ dated
____________:

ATTY. ARTURO PERALTA


Counsel for Gear Foods
Ground Floor, Daproza Bldg.,
Daproza Avenue
General Santos City RR# _____________ dated
______________:

44 | P a g e
45 | P a g e
Republic of the Philippines
6th MUNICIPAL CIRCUIT TRIAL COURT TAGOLOAN &
VILLANUEVA
Tagoloan, Misamis Oriental

Sps. Filomeno S. Salcedo Sr. Civil Case No. 2014-360


Represented by: Curo P.
salcedo, Sherly Salcedo
Cabugwas & Lamberto P.
Salcedo,
Plaintiffs,
FOR: UNLAWFUL DETAINER
-vs- AND DAMAGES

Ms. Lydia S. Maulas & Ms.


Aracelli S. Maulas,
Defendants
x- - - - - - - - - - - - - - - - /

MOTION FOR POSPONEMENT

Plaintiffs, by counsel unto the Honorable Court most


respectfully states, to wit;

That, the above-entitled case is set for hearing on


February 5, 2016 at 8:30 o’clock in the morning. Due to
conflict of schedule as undersigned counsel was previously
committed to appear for hearing in the case of,
Tamparong/Gungob vs. Rubin, before MTCC Branch 4
Cagayan de Oro City in the morning sessions, as counsel for
defendants he could not possibly attend to the hearing of
the above-entitled case before this Honorable Court, unless,
the same be cancelled and reset to February 12, 2015 at
8:30 o’clock in the morning

This motion is not intended for delay.

46 | P a g e
Wherefore it is most respectfully prayed of the
Honorable Court that the hearing scheduled on January 15,
2015 be cancelled and the same be reset to February 12,
2015 at 8:30 o’clock in the morning.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, (for Tagoloan, Misamis Oriental),


Philippines. January 9, 2014.

MERLIN P. CAIÑA & ASSOCIATES


Counsel for the Plaintiff
2/F Ligan Building
No. 188 Lapasan Highway
Lapasan Highway, Cagayan de Oro City
Tel. No. 8568238

MERLIN P. CAIÑA
IBP (OR) 1011647; 12.22.2015,CDOC for (2016)
PTR No.3040044; 12.22.2015,CDOC for (2016)
MCLE Compliance No. V- 0000702 10.29.14
TIN NO. 114-722-311 ; Roll No. 24443

Hon. Clerk of Court


MCTC Tagoloan-Villanueva
Misamis Oriental

Kindly, take notice that the above-entitled motion be


submitted to the Honorable Court immediately upon receipt t
hereof, sans oral arguments.

MERLIN P. CAIÑA

Copy furnished by Registered mail :

ASST. PROV. PROSECUTOR


Cagayan de Oro City

47 | P a g e
AUDIE G. PADUGANAN
No. 22 Gen. Wood Corner Bonifacio St.,
Zone 13 Poblacion, Tagoloan,
Misamis Oriental

Republic of the Philippines


DEPARTMENT OF JUSTICE

48 | P a g e
National Prosecution Service
OFFICE OF THE PROVINCIAL PROSECUTOR
Province of Misamis Oriental

APP ETHELINDA P. BACAL

WENDELYN BANAAG-REAL NPS NO. INV-15H-00466


Complainant,

-versus-
FOR: GRAVE THREATS
MELCHOR SABIO and GORIO
SABIO
Respondent,
x- - - - - - - - - - - - - - - - - -
- /

MOTION FOR EXTENSION OF TIME AND


POSPONEMENT

Respondent Defendants-appellants, by counsel unto the


Honorable Court most respectfully states, to wit;

That per Order of the Honorable Office dated


September 7, 2015 and which was received by the
undersigned counsel on September 14, 2015, respondents is
directed to submit their Counter-Affidavit within Ten (10)
days from receipt of the said Order. However, due to the
heavy legal works and almost daily appearances on Court,
the undersigned cannot possibly comply with the Order and
submit today the Counter-Affidavit and draft memorandum.
It was only today that the undersigned counsel formally
discuss the matter with the respondent.

Due to this predicament the undersigned respectfully


moves for an extension of FIFTEEN (15) days from today
within which to file her Counter-Affidavit on or before
October 6, 2015.

That instant motion is filed in good faith and never


intended to delay the proceedings of the Honorable Office.

WHEREFORE premises considered it is most


respectfully prayed unto the Honorable Court that an

49 | P a g e
extension of FIFTEEN (15) days be granted and respondent
be given until October 6, 2015 within which to file his
Counter-Affidavit.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, Philippines. September 21, 2015.

MERLIN P. CAIÑA & ASSOCIATES


Counsel for the respondents
2/F Ligan Building
No. 188 Lapasan Highway
Lapasan Highway, Cagayan de Oro City
Tel. No. 8568238

SYLVAN GERALD L. SABIO


IBP CDO (O.R. No.) 945557; Dec. 9, 2014
PTR CDO (O.R. No.) 2695855A, Dec. 11, 2014 MCLE
Compliance No. IV – 0020624, May 7, 2013
TIN 178-265-979; Roll No. 45542

Notice of Hearing

OFFICE OF THE PROVINCIAL PROSECUTOR


Cagayan de Oro City

WENDELYN BANAAG-REAL

Greetings!!

The undersigned will submit the foregoing motion for the


resolution and approval of the Honorable Office immediately
upon receipts sans oral arguments with or without the
appearances of parties.

Sylvan Gerald L. Sabio

Copy furnished by Registered mail :

WENDELYN BANAAG-REAL

50 | P a g e
J.R Borja Extension, Camaman-an
Cagayan de Oro City

epublic of the Philippines


DEPARTMENT OF JUSTICE
National Prosecution Service
OFFICE OF THE PROVINCIAL PROSECUTOR
Province of Misamis Oriental

EFREN S. BUHISAN NPS NO. X-05-INV-15G-


Complainant, 00377

-versus-

JEFFVIC O. ITO A.K.A FOR: MURER


“TAWING” ,

51 | P a g e
Respondent,
x- - - - - - - - - - - - - - - - - -
- /

MOTION FOR EXTENSION OF TIME AND


POSPONEMENT

Respondent Defendants-appellants, by counsel unto the


Honorable Court most respectfully states, to wit;

That per Order of the Honorable Office dated May 12,


2015 and which was received by the undersigned counsel on
May 21, 2015, complainant is directed to submit her verified
position paper and draft decision within fifteen (15) days
from receipt of the said Order. However, due to the heavy
legal works and almost daily appearances on Court, the
undersigned cannot possibly comply with the Order and
submit today the position paper and draft memorandum.

Due to this predicament the undersigned respectfully


moves for an extension of FIFTEEN (15) days from today
within which to file her Counter-Affidavit on or before
September 23, 2015.

That instant motion is filed in good faith and never


intended to delay the proceedings of the Honorable Office.

WHEREFORE premises considered it is most


respectfully prayed unto the Honorable Court that an
extension of FIFTEEN (15) days be granted and respondent
be given until September 23, 2015 within which to file his
Counter-Affidavit.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, Philippines. September 8, 2015.

MERLIN P. CAIÑA & ASSOCIATES


2/F Ligan Building
No. 188 Lapasan Highway
Lapasan Highway, Cagayan de Oro City
Tel. No. 8568238

52 | P a g e
SYLVAN GERALD L. SABIO
IBP CDO (O.R. No.) 945557; Dec. 9, 2014
PTR CDO (O.R. No.) 2695855A, Dec. 11, 2014 MCLE
Compliance No. IV – 0020624, May 7, 2013
TIN 178-265-979; Roll No. 45542

Notice of Hearing

HLURB Office
Northern Mindanao Region,
Cagayan de Oro City

ATTY. CHRISTER A. SORILLA

Greetings!!

The undersigned will submit the foregoing motion for the


resolution and approval of the Honorable Office immediately
upon receipts sans oral arguments with or without the
appearances of parties.

Sylvan Gerald L. Sabio

Copy furnished:

ATTY. CHRISTER A. SORILLA


c/o Communities Cagayan, Inc.,
2nd Floor, Pelaez Arcade II
R.N. Abjuela cor. J.P Rizal Sts.,
Cagayan de Oro City
Registry receipt No. _________date: June 5, 2015

53 | P a g e
REPUBLIC OF THE PHILIPPINES
National Capital Judicial Region
Metropolitan Trial Court
Branch 67
Makati City

People of the Philippines, Crim. Case No. 374644-45


-plaintiff

-versus-

June Rosqueta, For: Perjury


-accused
x- - - - - - - - - - - - - - - /

MOTION FOR POSPONEMENT

Accused by counsel1 unto the Honorable Court most


respectfully states, to wit;

That the above-entitled case is set for hearing on


September 4, 2015 at 8:30 o’clock in the morning. Due to
conflict of schedule as undersigned counsel was previously
committed to appear for hearing in the case of, PP. vs.
Wilfredo Babano, et. al., Criminal Case L-2102 for Estafa
before Regional Trial Court Branch 28, Lianga, Surigao del

1
Atty. Jose Conrado C. Sabio (nephew of the undersigned counsel) appear as counsel for the accuse during
the arraignment

54 | P a g e
Sur in the morning sessions, as counsel for private
complainant, he could not possibly attend to the hearing of
the above-entitled case before this Honorable Court, unless,
the same be cancelled and reset to October 9, 2015 at 8:30
o’clock in the morning. Attached herewith is the order of the
Regional Trial Court Branch 28, Lianga, Surigao del Sur and
marked as Annex “A”.

This motion is not intended for delay and filed in good


faith.

Wherefore it is most respectfully prayed of the


Honorable Court that the hearing scheduled on September
4, 2015 be cancelled and the same be reset to October 9,
2015 at 8:30 o’clock in the morning.

Other relief and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City (for Makati City) Philipines. August


27, 2015.

MERLIN P. CAINA & ASSOCIATES


Counsel for the accused
2/F Ligan Building
No. 188 Lapasan Highway
Lapasan Highway, Cagayan de Oro City
Tel. No. 8568238

SYLVAN GERALD L. SABIO


Lapasan, Cagayan de Oro City
IBP CDO (O.R. No.) 945557; Dec. 9, 2014 (for 2015
CDO)
PTR CDO (O.R. No.) 2695855A, Dec. 11, 2014 (for
2015 CDO)
MCLE Compliance No. V – 0009408, July 27, 2015
TIN 178-265-979; Roll No. 45542

Notice of Hearing

Hon. Clerk of Court


Metropolitan Trial Court
Branch 67
Makati City

55 | P a g e
Office of the City Prosecutor
Makati City
Please take notice that the undersigned will submit the
foregoing motion for the resolution on September 4, 2015 at
9:00 o’clock in the morning without appearances of the
undersigned counsel.

Sylvan Gerald L. Sabio

Copy furnished by Registered Mail


Office of the City Prosecutor
Makati City
RR# _______________ date __________:

Republic of the Philippines


REGIONAL TRIAL COURT
10TH Judicial Region
Branch 10
Malaybalay City

IN THE MATTER FOR THE SPECIAL PROCEDDING CASE


ISSUANCE OF LETTER OF NO. 3209-
ADMINISTRATION OF
INTESTATE ESTATA OF THE
LATE ESTILITA SIDLAO AND
SETTLEMENT OF CLAIM
AGAINST THE ESTATE,

56 | P a g e
-versus-

CAPITOL UNIVERSITY
MEDICAL CITY FOUNDATION,
INC., HEREIN REPRESENTED
BY ECILIETO A. LEGASPI,
Petitioner-Claimant,
x- - - - - - - - - - - - - - - - /

MOTION FOR POSPONEMENT

Petitioner, by counsel unto the Honorable Court most


respectfully states, to wit;

That, the above-entitled case is set for hearing on June


25, 2015 at 8:30 o’clock in the morning. Due to conflict of
schedule as undersigned counsel was previously committed
to appear for hearing in the case of, PP. vs. Petalcurin.,
before Regional Trial Court Branch 41 Cagayan de Oro City
in the morning sessions, as counsel for defendant Accused
Dennis Petalcurin he could not possibly attend to the hearing
of the above-entitled case before this Honorable Court,
unless, the same be cancelled and reset to July 15, 2015 at
8:30 o’clock in the morning. Attached herewith is the order
of the Regional Trial Court Branch 41, Cagayan de Oro City
and marked as Annex “A”.

This motion is not intended for delay.

Wherefore it is most respectfully prayed of the


Honorable Court that the hearing scheduled on June 25,
2015 be cancelled and the same be reset to July 15, 2015 at
8:30 o’clock in the morning.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, (for Malaybalay City), Philippines.


June 22, 2015.

CAIÑA CAIÑA SABIO LAW OFFICE


Counsel for Plaintiff
2/F Ligan Building
188 Lapasan Highway

57 | P a g e
Lapasan, Cagayan de Oro City

SYLVAN GERALD L. SABIO


IBP CDO (O.R. No.) 945557; Dec. 9,
2014
PTR CDO (O.R. No.) 2695855A, Dec. 11,
2014
MCLE Compliance No. IV – 0020624,
May 7, 2013
TIN 178-265-979; Roll No. 45542

Notice of Hearing

Hon. Clerk of Court


RTC Br. 10, Malaybalay City,

Atty. Sharon D. Daral

Kindly, take notice that the above-entitled motion be


submitted to the Honorable Court immediately upon receipt
thereof, sans oral arguments.

SYLVAN GERLAD L. SABIO

Explanation and Proof of Service

Copy of the foregoing motion was served to Atty.


Sharon D. Daral by registered mail due to distance that
renders personal service impossible.

SYLVAN GERLAD L. SABIO

Copy furnished:

Atty. Sharon D. Daral


2/F Ma. Building
Rizal-San Isidro Street
Malaybalay City Bukidnon
RR No.: ____________ date _________

58 | P a g e
Republic of the Philippines
REGIONAL TRIAL COURT
10TH Judicial Region
Branch 10
Malaybalay City

IN THE MATTER FOR THE SPECIAL PROCEDDING CASE


ISSUANCE OF LETTER OF NO. 3209-
ADMINISTRATION OF
INTESTATE ESTATA OF THE
LATE ESTILITA SIDLAO AND
SETTLEMENT OF CLAIM
AGAINST THE ESTATE,

-versus-

CAPITOL UNIVERSITY
MEDICAL CITY FOUNDATION,
INC., HEREIN REPRESENTED
BY ECILIETO A. LEGASPI,
Petitioner-Claimant,
x- - - - - - - - - - - - - - - - /

MOTION FOR POSPONEMENT

Petitioner, by counsel unto the Honorable Court most


respectfully states, to wit;

That, the above-entitled case is set for hearing on June


25, 2015 at 8:30 o’clock in the morning. Due to conflict of
schedule as undersigned counsel was previously committed
to appear for hearing in the case of, PP. vs. Petalcurin.,
before Regional Trial Court Branch 41 Cagayan de Oro City
in the morning sessions, as counsel for defendant Accused
Dennis Petalcurin he could not possibly attend to the hearing
of the above-entitled case before this Honorable Court,
unless, the same be cancelled and reset to July 15, 2015 at
8:30 o’clock in the morning. Attached herewith is the order
of the Regional Trial Court Branch 41, Cagayan de Oro City
and marked as Annex “A”.

This motion is not intended for delay.

Wherefore it is most respectfully prayed of the


Honorable Court that the hearing scheduled on June 25,

59 | P a g e
2015 be cancelled and the same be reset to July 15, 2015 at
8:30 o’clock in the morning.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, (for Malaybalay City), Philippines.


June 22, 2015.

CAIÑA CAIÑA SABIO LAW OFFICE


Counsel for Plaintiff
2/F Ligan Building
188 Lapasan Highway
Lapasan, Cagayan de Oro City

SYLVAN GERALD L. SABIO


IBP CDO (O.R. No.) 945557; Dec. 9,
2014
PTR CDO (O.R. No.) 2695855A, Dec. 11,
2014
MCLE Compliance No. IV – 0020624,
May 7, 2013
TIN 178-265-979; Roll No. 45542

Notice of Hearing

Hon. Clerk of Court


RTC Br. 10, Malaybalay City,

Atty. Sharon D. Daral

Kindly, take notice that the above-entitled motion be


submitted to the Honorable Court immediately upon receipt
thereof, sans oral arguments.

SYLVAN GERLAD L. SABIO

Explanation and Proof of Service

Copy of the foregoing motion was served to Atty.


Sharon D. Daral by registered mail due to distance that
renders personal service impossible.

SYLVAN GERLAD L. SABIO

60 | P a g e
Copy furnished:

Atty. Sharon D. Daral


2/F Ma. Building
Rizal-San Isidro Street
Malaybalay City Bukidnon
RR No.: ____________ date _________

61 | P a g e
Republic of the Philippines
REGIONAL TRIAL COURT OF MISAMIS ORIENTAL
10TH Judicial Region
Branch 44
Initao, Misamis Oriental

IN RE: PETITION FOR LRC NO. 2012-49


ISSUANCE OF ORIGINAL
CERTIFICATE OF TITLE BASE
ON A FINAL DECREE NO.
746850, DATED MAY 5,
1941 PERTAINING TO LOT
NO. 11608, B.L. CAD-237,
B.L CASE NO. 13,
CADASTRAL CASE NO. 26,
LRC CAD. REC. NO. 1591,
OF THE CADASTRAL SURVEY
OF CAGAYAN, PROVINCE OF
MISAMIS ORIENTAL

BERNARDINA L. NAGAC,
herein Represented by
ADRIAN L. NAGAC,
Petitioner
x- - - - - - - - - - - - - - - /

COMPLIANCE

Petitioner by counsel unto the Honorable Court most


respectfully states, to wit;

62 | P a g e
That in compliance to the Order of the Honorable Court
dated March 12, 2015 and received by the undersigned
counsel on April 6, 2015, copy of the aforementioned Order
and petition with attached was to serve to the following, to
wit;

Land Registration Authority


East Avenue cr. NIA Road
Diliman Quezon City
Registry receipt # _____________date: June 11, 2015

Land Management Bureau


Plaza Cervantes
Binondo, Manila
Land Management Services
Registry receipt # _____________date: June 11, 2015

DENR-Region 10
Puntdo, Cagayan de Oro City
Registry receipt # _____________date: June 11, 2015

Office of the Solicitor General


134 Amorsolo Street
Legaspi Village
Makati City
Registry receipt # _____________date: June 11, 2015

Regional Director
DENR –Region 10
Puntod
Cagayan de Oro City
Registry receipt # _____________date: June 11, 2015

CENRO Officer
DENR CENRO
Regional Office 10
Cagayan de Oro City
Registry receipt # _____________date: June 11, 2015

Forest Management Bureau

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DENR 10
Cagayan de Oro City
Registry receipt # _____________date: June 11, 2015

Respectfully submitted. June 11, 2015.

Cagayan de Oro City (for Initao, Misamis Oriental),


Philippines.

MERLIN P. CAIÑA & ASSOCIATES


2/F Ligan Building
No. 188 Lapasan Highway
Lapasan Highway, Cagayan de Oro City
Tel. No. 8568238

SYLVAN GERALD L. SABIO


IBP CDO (O.R. No.) 945557; Dec. 9, 2014
PTR CDO (O.R. No.) 2695855A, Dec. 11, 2014 MCLE
Compliance No. IV – 0020624, May 7, 2013
TIN 178-265-979; Roll No. 45542

64 | P a g e
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Republic of the Philippines
Office of the President
HOUSING AND LAND USE REGULATORY BOARD
Northern Mindanao Region, Cagayan de Oro City

NORJANA D. SARIP HLURB CASE NO. NMR-REM-


Complainant, 031115-044

-versus-

CROWN COMMUNITIES FOR: SPECIFIC


(CAGAYAN), INC., PERFORMANCE AND
Respondent, DAMAGES
x- - - - - - - - - - - - - - - /

URGENT EX-PARTE MOTION FOR EXTENSION OF TIME

Defendants-appellants, by counsel unto the Honorable


Court most respectfully states, to wit;

That per Order of the Honorable Office dated May 12,


2015 and which was received by the undersigned counsel on
May 21, 2015, complainant is directed to submit her verified
position paper and draft decision within fifteen (15) days

66 | P a g e
from receipt of the said Order. However, due to the heavy
legal works and almost daily appearances on Court, the
undersigned cannot possibly comply with the Order and
submit today the position paper and draft memorandum.

Due to this predicament the undersigned respectfully


moves for an extension of FIFTEEN (15) days from today
within which to file her position paper and draft decision on
or before June 20, 2015.

That instant motion is filed in good faith and never


intended to delay the proceedings of the Honorable Office.

WHEREFORE premises considered it is most


respectfully prayed unto the Honorable Court that an
extension of ten (10) days be granted and defendants-
appellants be given until January 12, 2009 within which to
file its Appellant’ Brief.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, Philippines. June 5, 2015.

MERLIN P. CAIÑA & ASSOCIATES


2/F Ligan Building
No. 188 Lapasan Highway
Lapasan Highway, Cagayan de Oro City
Tel. No. 8568238

SYLVAN GERALD L. SABIO


IBP CDO (O.R. No.) 945557; Dec. 9, 2014
PTR CDO (O.R. No.) 2695855A, Dec. 11, 2014 MCLE
Compliance No. IV – 0020624, May 7, 2013
TIN 178-265-979; Roll No. 45542

Notice of Hearing

HLURB Office
Northern Mindanao Region,
Cagayan de Oro City

ATTY. CHRISTER A. SORILLA

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Greetings!!

The undersigned will submit the foregoing motion for the


resolution and approval of the Honorable Office immediately
upon receipts sans oral arguments with or without the
appearances of parties.

Sylvan Gerald L. Sabio

Copy furnished:

ATTY. CHRISTER A. SORILLA


c/o Communities Cagayan, Inc.,
2nd Floor, Pelaez Arcade II
R.N. Abjuela cor. J.P Rizal Sts.,
Cagayan de Oro City
Registry receipt No. _________date: June 5, 2015

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Republic of the Philippines
MUNICIPAL TRIAL COURT IN CITIES
12th Judicial Region
Branch 2, Iligan City

THE PEOPLE OF THE Crim. Case No. 10-348; 10-


PHILIPPINES 349; 10-350; 10-351; 10-
Plaintiff, 352; 10-353; 10-354;

-versus-
-
RICARDO SANCHEZ, For: VIOLATION OF BP 22
Accused,
x- - - - - - - - - - - - - - - - /

A. MEMORANDUM FOR THE ACCUSED

Accused, by counsel and in compliance of the order of


the Honorable Court, most respectfully submits this
MEMORANDUM.

B. STATEMENT OF THE CASE

While accused may partially admits plaintiff’s assertions


on the statement of the case, with due respect, the same is
however subject to the admitted evidence on record which

69 | P a g e
would constitute as exculpatory or exempting facts tending
to clear, absolved or denial of any criminal or civil liability on
the accused, as hereunder stated as:

C. COUNTER-STATEMENT OF FACTS

C-1 The filling and prosecution of the above criminal


case were on the strength of the “Affidavit-Complaint” of the
Lalit K. Sehgal, an alleged Managing Director of Global Steel
Philipines (SPV-AMC) dated 13 July 2009 (RECORDS).

C-2 The filing and prosecution of the respective cases


must FAIL. And DISMISSED outright for being inherently and
FATALLY DEFECTIVE for WANT OF AUTHORITY, of the
purported complainant Lalit K. Sehgal in having done so.

C-3 In the instant cases, what we have is the cold and


stubborn fact that from the inception is the sole Affidavit-
Complaint of Lalit K. Sehgal and it is never mentioned that
he was authorized by the Board of Directors of the supposed
private offended party Corporation (Global Steel Philippines).
Naturally, in the Resolution of the Honorable Office of the
City Prosecution of Iligan City, there is no assertion that Mr.
Sehgal was indeed authorized by the Corporation
(RECORDS).

C-4 Out of the blue, there is this professed “Secretary


Certificate” presented by the prosecution through the private
prosecutor singed by one Ma. Romela M. Bengzon marked as
Exh. “P” to “P-1”.

C-5 Under the Corporation Code of the Philippines (BP.


# 68) only the Board of Directors has the power to sue as
provided for under Section 36 of the same Code.

BOARD OF DIRECTORS

“It is the directing and controlling body of a


corporation. It is a creations of the stockholders and drives
its power to control and direct the affairs of the corporation
from them. Directors occupy a position of trusteeship in
relation to the stockholders in the sense that the board
should exercise not only care and diligence but utmost good
faith in the management of the corporate affairs. (Legarda
v. La Previsoria Filipina, 66 Phil. 723 (1938).

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C-6 Law and jurisprudence have it that power to sue
and be sued is within the exclusive powers of the Board of
Directors of the Corporation (ABS-CBN v. CA, 301 SCRA 572
[1999].

C-7 The apparent “Secretary Certificate” of Ma. Romela


M. Benzon marked as Exhs. “P” to P-1” of the prosecutiob
with due respect, does not deserve to be dignified because
it bears no resolution number, undated and not under
oath. On account of the surrounding circumstances of the
same claimed and questioned resolution, a question may be
ask why this is so? We cannot venture to say that this
anybody’s guess since we are in the guessing game.

C-8 Here, we are trying criminal case against the


accused, and we cannot also draw any presumption because
of the lurking danger against the rights of the accused.

C-9 Against the same “Secretary Certificate” Exhs. “P”


“P-1”, accused submits that the same does not satisfy or
justify the mandated requirements of the law, much less
binds the complainant Corporation.

C-10 These case are prosecuted no less than by the


private prosecutor and under Article 100 of the Revised
Penal Code it provides.

“Art. 100. Civil liability of a person guilty of felony-


Every person criminally liable for a felony is also civilly
liable.”

So, the civil, aspect of these cases are instituted.

C-11 Further, thru the private prosecutor the


prosecution also presented another “Secretary Certificate”
now dated September 5, 2012 and marked as Exhs. “S”
claiming that a certain Mr. Sangram Mohante or Antoine
Seva of having authorized to represent the Corporation. The
striking difference between prosecution’s Exhs. “P” to “P-1”
and “S” is very clear, there is no need of elaboration. Exh.
“S” cannot ratify nor confirm Exhs. “P” & “P-1”. If the
proceedings of these cases will be allowed to proceed on the
basis of Exh. “S” accused submits that it legally and
procedurally not possible and valid, because the bottom

71 | P a g e
line of the instant motion is the very questioned of the
legality of the Affidavit-Complaint of Mr. Lalit K. Sehgal
dated July 13, 2009 and we will be throwing the entire
proceedings of these cases into a trial by anachronism.

C-12 When this is issues was brought out by defense


the last time this case was heard and there was that initial
verbal scuffle on both sides, the prosecution admitted that
the same secretary certificate (Exhs. “P” & “P-1”) need not
be under oath in a corporation query may be ask why is it
that their secretary certificate marked as their Exh. “S” at
this time is under oath. Is the prosecution now instituting a
case of double standard?

C-13 With due respect, to such claim by the


prosecution still it is the unwavering stance of the defense
that said kind of document (Exhs. “P” & “P-1”) should have
been and should be under oath since the prosecution nhas
its own policy, likewise, courts should have its own, with
more reason in these cases which is an adversarial
proceedings.

C-14 Anent the Affidavit-Complaint if Lalit K. Sehgal,


the same cannot be dignified and it has remained Hearsay
and a mere scrap of paper because Lalit K. Sehgal has
never been presented in court having testified thereof as
required by the rules.

C-15 Accused has presented as his documentary proofs


Exhs. “1” to “1-A-2”. Likewise, presented Exhs. “2” to “2-J”
consisting of Banco De Oro (BDO) Cash Deposits Slips
bearing their respective dates showing cash payments
acknowledged having been received by Cashier-Witness Ms.
Alei Dorotheo made by the accused to complainants,
showing the fact that before the filling of the above entitled
cases before the City Prosecution of Iligan City on July 13,
2009, accused have already partially paid in the total
amount of Two Million Three Hundred Four Thousand
Pesos (Php 2,304,000.00) of the total obligation of Ten
Millio Nine Hundred Eighty Eight Thousand Five
Hundred Twenty Pesos (Php 10,988,520.00) to the
private complainant this fact of NOVATION has interplayed
in the process as the usual relationship between the
parties. Aside from an additional amount of Two Hundred
Fifty Thousand Pesos (Php 250,000.00) and another amount

72 | P a g e
of One Hundred Thousand Pesos (Php 100,000.00) during
the preliminary investigation and Mediation stages of the
above entitled cases,

D. STATEMENT OF THE ISSUES

D-1 WHETHER OR NOT ACCUSED IS GUILTY OF


THE CHARGES OF VIOLATION BATAS PAMBANSA
BLG 22

D-2 WHETHER OR NOT NOVATION HAD


INYERPLAYED IN THE RELATIONSHIP OF THE
PARTIES AND.

D-3 WHETHER OR NOT THE PRIVATE


COMPLAINANT PRESIDENT, MR. LALIT SEHGAL
WAS CLOATED WITH AUTHORITY TO FILE THE
COMPLAINT:

E DISCUSSIONS & ARGUMETS

E-1 The elements of the complained violations of Batas


Pambansa Blg. 22 have not been proven especially on the
issue, whether or not accused received the supposed
demand letter.

E-2 Whether or not novation had interplayed in the


relationship of the parties.

Novation, intervened in the transactions.


Evidence on record proved that Exh. “2” to “2-J”
consisting of Banco de Oro Cash Deposits Slips in the total
amount of Two Million Three Hundred Four Pesos (Php
2,304,000.00) was paid by the accused before the filing of
the above entitled cases before the City Prosecution Office of
Iligan City on July 13, 2009 of the total obligation of Ten
Million Nine Hundred Eighty Eight Thousand Five Hundred
Twenty Pesos (Php 10,988,520.00) to the private
complainant.

While it is true that novation does not extinguish


criminal liability, it may however, prevent the rise of criminal
liability as long as it occurs prior to the filing of the criminal

73 | P a g e
information in court Thus, in Gonzales vs. Serrano (25 SCRA
64, 69 [1968].

As pointed out in People vs. Neri, novation prior to the


filing of the criminal information – as in the case at bar –
may convert the relation between the parties into an
ordinary creditor-debtor relation, and place the complainant
in estoppel to insist on the original transaction or “cast
doubt on the true nature” thereof.

Again, in the latest case of Ong vs, Court of Appeals (L-


58476, 124 SCRA 578, 580-581 [1983] ), this Court
reiterated the ruling in People vs. Nery ( 10 SCRA 244
[1964]),

The novation theory may perhaps apply to the filing of


the criminal information in court by state prosecutors
because up to that time the original trust relation may be
converted by the parties into an ordinary creditor-debtor
situation, thereby placing the complainant in estoppel to
insist on the original trust.

It may be observed in this regard that novation is not


of the means recognized by the Penal Code whereby criminal
liability can be extinguished; hence, the role of novation
may only be to either prevent the rise of criminal liability or
to cast doubt on the true nature of the original basic
transaction, whether or not it was such that its breach would
not give rise to penal responsibility, as when money loaned
is made to appear as a deposit, or other similar disguise is
resorted to (cf. Abeto vs. People, 90 Phil. 581; U.S vs.
Villareal, 27 Phil. 481).

The above entitled cases are cited in G.R No. L-60033


April 4, 1984, entitled Teofisto Guinggona, Jr., Et. al., vs.
The City Fiscal of Manila. Hon. Jose B. Flaminiano, Et. al.,.

F WHETHER OR NOT THE PRIVATE COMPLAINANT


PRESIDENT, MR. LALIT SEHGAL WAS CLOATED WITH
AUTHORITY TO FILE THE COMPLAINT

F-1 As discussed on the above Counter-Statement of


Facts the same Lalit Sehgal had not been authorized by any
authority in the institution of the above entitled cases.
Likewise, his Affidavit of Complaint must not be dignified

74 | P a g e
since with more reason that he was never presented to
testify in the cases, hence, his Affidavit is hearsay.

WHEREFORE, against the foregoing background it is


most respectfully prayed of the Honorable Court that the
cases against the accused be dismissed for lack of merit.

Respectfully Submitted.

Cagayan de Oro City, (for Iligan City), Philippines. May


14, 2015.

MERLIN P. CAIÑA & ASSOCIATES


2/F Ligan Building
188 Lapasan Highway
Lapasan, Cagayan de Oro City

MERLIN P. CAIÑA
Counsel for Accused
1150 Camama-an, Cagayan de Oro City
IBP (OR) 945556; 12.9.2014,CDOC for
(2015)
PTR No.2695856 ; 12.11.2014,CDOC for
(2015)
TIN NO. 114-722-311 ; Roll No. 24443
MCLE Compliance No. V- 0000702
10.29.14

Hon. Clerk of Court


MTCC Branch 2, Iligan City

REX DISTOR CALMERIN


Counsel for Plaintiff

Explanation and Proof of Service

Copy of the foregoing pleading was served to Atty. Rex


Distor Calmarin, by LBC, due to distance that renders
personal service impossible.

75 | P a g e
MERLIN P. CAIÑA

Copy furnished:

REX DISTOR CALMARIN


#14 Purok Maligaya, Carbide Village
Brgy. Tubod, Iligan City
RR# _______________ dated __________;

76 | P a g e
MOTION FOR CLARIFICATION WITH POSPONEMENT

Undersigned, counsel of the accused to this Honorable


Court most respectfully states, THUS;

1. In its Order of this Honorable Court in the above entitled


cases dated 5 September 2014, which was received on
19 September 2014, undersigned filed the Formal Offer
of defense exhibits on 30 September 2014;

2. However, up to this writing undersigned has not


received a ruling of defense formal offer of exhibits, the
reason why defense has not filed his desired
memorandum;

3. Be that as it may, undersigned moves that he be clarified


on the ruling of defense formal offer of exhibits.
Likewise, the notice of hearing for promulgation of
decision of the above entitled cases be reset to another
date considering that he has been previously committed
to appear for hearing (On Liquidator’s Report) in Spec.
Proc. Case No. 2013-029, before Regional Trial Court,
Branch 18, Cagayan de Oro City, set on the same date
March 18, 2015.

Wherefore it is most respectfully prayed of the


Honorable Court that the defense be clarified of the ruling
on the formal offer of their exhibits and the hearing of the
promulgation of decision on the September 18, 2015 be
cancelled and the same be reset to April 20, 2015 at 9:30
o’clock in the morning.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, (for Iligan City), Philippines.


March 9, 2015.

77 | P a g e
Notice of Hearing

Hon. Clerk of Court


RTC Branch 38, Dumaguete City

Atty. Jose A. Abiera


Counsel for Plaintiff

Greetings!!

The undersigned will submit the foregoing motion for the


resolution and approval of the Honorable Court immediately
upon receipts sans oral arguments and appearances of
parties.

Sylvan Gerald L. Sabio

Explanation and Proof of Service

Copy of the foregoing pleading was served to Atty. Jose A.


Abiera, by registered mail, due to distance that renders
personal service impossible.

Sylvan Gerald L. Sabio

Copy furnished:

Atty. Jose A. Abiera


Poblacion, Sibulan
Negros Oriental
Hall of Justice
Cagayan de Oro City
Registry receipt No. _________date: ___________

78 | P a g e
MERLIN P. CAIÑA & ASSOCIATES
2/F Ligan Building
188 Lapasan Highway
Lapasan, Cagayan de Oro City

MERLIN P. CAIÑA
Counsel for Accused
1150 Camama-an, Cagayan de Oro City
IBP (OR) 945556; 12.9.2014,CDOC for
(2015)

79 | P a g e
PTR No.2695856 ; 12.11.2014,CDOC for
(2015)
TIN NO. 114-722-311 ; Roll No. 24443
MCLE Compliance No. V- 0000702
10.29.14

Hon. Clerk of Court


MTCC Branch 2
Iligan City

Atty. Rex Distor Calmerin

Kindly, take notice that the above-entitled motion is


submitted for the consideration and resolution of the

80 | P a g e
Honorable Court, immediately upon receipt hereof sans oral
arguments.

MERLIN P. CAIÑA

Copy Furnished By LBC;

Atty. Rex Distor Calmerin


#14 Purok Maligaya, Carbide Village
Brgy. Tubod, Iligan City
LBC _______________ dated March 9, 2015

Republic of the Philippines


MUNICIPAL TRIAL COURT IN CITIES
Tagum City, Davao del Norte

PEOPLE OF THE PHILIPPINES Crim. Case No. 30433-14 &


Complainant, 30434-14

-versus-

81 | P a g e
ROSALINA C. SANCHEZ, Nature: VIOLATION OF BP 22
Accused,
x- - - - - - - - - - - - - - - - /

MOTION FOR POSPONEMENT

Accused, by counsel unto the Honorable Court most


respectfully states, to wit;

That, the above-entitled case is set for initial hearing


on January 19, 2015 at 8:30 o’clock in the morning. Due to
conflict of schedule as undersigned counsel was previously
committed to appear for hearing in the case of, Halibas vs.
Rural Bank of Talisayan., before Regional Trial Court Branch
38 Cagayan de Oro City in the morning sessions, as counsel
for defendant Rural Bank of Talisayan he could not possibly
attend to the hearing of the above-entitled case before this
Honorable Court, unless, the same be cancelled and reset to
February 27, 2015 at 8:30 o’clock in the morning

This motion is not intended for delay.

Wherefore it is most respectfully prayed of the


Honorable Court that the hearing scheduled on January 19,
2015 be cancelled and the same be reset to February 27,
2015 at 8:30 o’clock in the morning.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, (for Tagum City), Philippines.


January 9, 2014.

CAIÑA CAIÑA SABIO LAW OFFICE


Counsel for Plaintiff
2/F Ligan Building
188 Lapasan Highway
Lapasan, Cagayan de Oro City

MERLIN P. CAIÑA
Counsel for Accused
1150 Camama-an, Cagayan de Oro City
IBP (OR) 945556; 12.9.2014,CDOC for
(2015)

82 | P a g e
PTR No.2695856 ; 12.11.2014,CDOC for
(2015)
TIN NO. 114-722-311 ; Roll No. 24443
MCLE Compliance No. IV-
0007735,9.11.2012

Hon. Clerk of Court


MTCC Tagum, City
Davao del Norte

83 | P a g e
Kindly, take notice that the above-entitled motion be
submitted to the Honorable Court immediately upon receipt t
hereof, sans oral arguments.

MERLIN P. CAIÑA

JOSE MIGUEL C. VELOSO IV


Coca-cola Compound, Aluba Subdivision
Macasandig, Cagayan de Oro City

OFFICE OF THE SOLICITOR GENERAL


134 Amorsolo Street

84 | P a g e
Legaspi Village
Makati City Metro Manila

85 | P a g e
86 | P a g e
Republic of the Philippines
6th MUNICIPAL CIRCUIT TRIAL COURT TAGOLOAN &
VILLANUEVA
Tagoloan, Misamis Oriental

Sps. Filomeno S. Salcedo Sr. Civil Case No. 2014-360


Represented by: Curo P.
salcedo, Sherly Salcedo
Cabugwas & Lamberto P.
Salcedo,
Plaintiffs,
FOR: UNLAWFUL DETAINER
-vs- AND DAMAGES

Ms. Lydia S. Maulas & Ms.


Aracelli S. Maulas,
Defendants
x- - - - - - - - - - - - - - - - /

MOTION FOR POSPONEMENT

Plaintiffs, by counsel unto the Honorable Court most


respectfully states, to wit;

That, the above-entitled case is set for initial hearing


on January 15, 2015 at 8:30 o’clock in the morning. Due to
conflict of schedule as undersigned counsel was previously
committed to appear for hearing in the case of, People vs.
Joseph Jimenez et. al., before Regional Trial Court Branch 24
Cagayan de Oro City in the morning sessions, as counsel for
accused Jimenez he could not possibly attend to the hearing
of the above-entitled case before this Honorable Court,
unless, the same be cancelled and reset to February 12,
2015 at 8:30 o’clock in the morning

87 | P a g e
This motion is not intended for delay.

Wherefore it is most respectfully prayed of the


Honorable Court that the hearing scheduled on January 15,
2015 be cancelled and the same be reset to February 12,
2015 at 8:30 o’clock in the morning.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, (for Tagoloan, Misamis Oriental),


Philippines. January 9, 2014.

CAIÑA CAIÑA SABIO LAW OFFICE


Counsel for Plaintiff
2/F Ligan Building
188 Lapasan Highway
Lapasan, Cagayan de Oro City

MERLIN P. CAIÑA
1150 Camama-an, Cagayan de Oro City
IBP (OR) 945556; 12.9.2014,CDOC for
(2015)
PTR No.2695856 ; 12.11.2014,CDOC for
(2015)
TIN NO. 114-722-311 ; Roll No. 24443
MCLE Compliance No. IV-
0007735,9.11.2012

Hon. Clerk of Court


MCTC Tagoloan-Villanueva
Misamis Oriental

Kindly, take notice that the above-entitled motion be


submitted to the Honorable Court immediately upon receipt t
hereof, sans oral arguments.

MERLIN P. CAIÑA

88 | P a g e
Republic of the Philippines
REGIONAL TRIAL COURT
10th Judicial Region
Branch 26
Medina, Misamis Oriental

RURAL BANK OF TALISAYAN, Civil Case No. 1068-M


(Mis. Or.), Inc.,
Plaintiff,

-vs-

GLORIA TAMAYO, ET. AL., FOR: COLLECTION OF SUM


Defendants OF MONEY WITH DAMAGES
x- - - - - - - - - - - - - - - - /

MOTION FOR POSPONEMENT

Plaintiff, by counsel unto the Honorable Court most


respectfully states, to wit;

That, the above-entitled case was set for hearing on


August 7, 2014at 8:30 o’clock in the morning. Due to
conflict of schedule as undersigned counsel was previously
committed to appear for hearing in the cases of, Jusayan,
et. al., vs. Bagares et. al., before Regional Trial Court
Branch 21 in the morning sessions, as evidence by an order
copy of which is hereto integrally attached as “Annex A”,

89 | P a g e
he could not possibly attend to the hearing of the above-
entitled case before this Honorable Court, unless, the same
be cancelled and reset to August 14, 2014 8:30 o’clock in
the morning

This motion is not intended for delay.

Wherefore it is most respectfully prayed of the


Honorable Court that the hearing scheduled on August 7,
2014 be cancelled and the same be reset to August 14, 2014
at 8:30 o’clock in the morning.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, (for Medina, Misamis Oriental),


Philippines. July 23, 2014.

CAIÑA CAIÑA SABIO LAW OFFICE


Counsel for Plaintiff
2/F Ligan Building
188 Lapasan Highway
Lapasan, Cagayan de Oro City

MERLIN P. CAIÑA
Counsel for the Petitioners
1150 Camama-an, Cagayan de Oro City
IBP (OR) 945269 ; 01.2.2014,CDOC
PTR No.2504591 ; 01.8.2014,CDOC
TIN NO. 114-722-311 ; Roll No. 24443
MCLE Compliance No. IV-
0007735,9.11.2012

Notice of Hearing
Hon. Clerk of Court
RTC Br. 26 Medina,
Misamis Oriental

Kindly, take notice that the above-entitled motion be


submitted to the Honorable Court immediately upon receipt t
hereof, sans oral arguments.

MERLIN P. CAIÑA

90 | P a g e
Explanation and Proof of Service

Copy of the foregoing motion was served to Atty.


Michael Roa and Atty. Antonio Amarga by registered mail
and personal delivery respectively.

MERLIN P. CAIÑA

Copy furnished:

Atty. Antonio Amarga


16 Pabayo St.
Cagayan de Oro City RR No.: ____________ date
_________

Atty. Michael Roa


Balingasag,
Misamis Oriental By: ________________date __________

91 | P a g e
92 | P a g e
Republic of the Philippines
7th Judicial Region
REGIONAL TRIAL COURT OF NEGROS ORIENTAL
Branch 38, Dumaguete City

RUSCO MOTORS, INC., Civil Case No. AP-05-14-145


represented by ENGR.
ROBERTO R. RAMA-
UYPITCHING, ETL. AL.,
Plaintiffs,

-vs-

LEONARDO M. BARRION FOR: COLLECTION OF SUM


(maker) and MINDA T. OF MONEY
BARRION (co-maker),
Defendants
x- - - - - - - - - - - - - - - - - -
- /

MOTION FOR EXTENSION OF TIME

Defendants-appellants, by counsel unto the Honorable


Court most respectfully states, to wit;

That per Order of the Honorable Court dated _____ and


which was received by the undersigned counsel on
_________, defendant-appellants are directed to submit
their Appellant’s Brief within fifteen (15) days from receipt of
the said Order. However, due to the heavy legal works and
almost daily appearances on Court, the undersigned cannot
possibly comply with the Order.

Due to this predicament the undersigned respectfully moves


for an extension of thirty (30) days from June 24, 2014
within which to file their Appellant’s Brief whixh is on or
before July 24, 2014

That instant motion is filed in good faith and never intended


to delay the proceedings of the Honorable Court;

WHEREFORE premises considered it is most respectfully


prayed unto the Honorable Court that an extension of ten
(10) days be granted and defendants-appellants be given

93 | P a g e
until January 12, 2009 within which to file its Appellant’
Brief.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, (for Dumaguete City),


Philippines. July 22, 2014.

CAINA CAINA SABIO LAW OFFICE


Counsel for the plaintiff
2/F Ligan Building
No. 188 Lapasan Highway
Lapasan Highway, Cagayan de Oro City
Tel. No. 8568238

SYLVAN GERALD L. SABIO


IBP CDO (O.R. No.) 945207; Dec. 18, 2013 (for
2014)
PTR CDO (O.R. No.) 2506782A, Dec. 18, 2013 (for
2014)
MCLE Compliance No. III-019717, January 5, 2011
MCLE Compliance No. IV – 0020624, May 7, 2013
TIN 178-265-979; Roll No. 45542

Notice of Hearing

Hon. Clerk of Court


RTC Branch 38, Dumaguete City

Atty. Jose A. Abiera


Counsel for Plaintiff

Greetings!!

The undersigned will submit the foregoing motion for the


resolution and approval of the Honorable Court immediately
upon receipts sans oral arguments and appearances of
parties.

Sylvan Gerald L. Sabio

94 | P a g e
Explanation and Proof of Service

Copy of the foregoing pleading was served to Atty. Jose A.


Abiera, by registered mail, due to distance that renders
personal service impossible.

Sylvan Gerald L. Sabio

Copy furnished:

Atty. Jose A. Abiera


Poblacion, Sibulan
Negros Oriental
Hall of Justice
Cagayan de Oro City
Registry receipt No. _________date: ___________

Republic of the Philippines


REGIONAL TRIAL COURT
10th Judicial Region
Branch 26
Medina, Misamis Oriental

RURAL BANK OF TALISAYAN, Civil Case No. 1068-M


(Mis. Or.), Inc.,
Plaintiff,

-vs-

GLORIA TAMAYO, ET. AL., FOR: COLLECTION OF SUM


Defendants OF MONEY WITH DAMAGES
x- - - - - - - - - - - - - - - - /

MOTION POSPONEMENT

95 | P a g e
Plaintiff, by counsel unto the Honorable Court most
respectfully states, to wit;

That, the above-entitled case was set for hearing on


June 26, 2014 at 8:30 o’clock in the morning. Due to conflict
of schedule as undersigned counsel was previously
committed to appear for hearing in the cases of, Jusayan,
et. al., vs. Bagares et. al., before Regional Trial Court
Branch 21, and Gungog vs. Tan before Regional Trial Court
Branch 17 all of Cagayan de Oro City, in the morning
sessions, he could not possibly attend to the hearing of the
above-entitled case before this Honorable Court, unless, the
same be cancelled and reset to July 10, 2014 at 8:30 o’clock
in the morning

This motion is not intended for delay.

Wherefore it is most respectfully prayed of the


Honorable Court that the hearing scheduled on June 26,
2014 be cancelled and the same be reset to July 10, 2014 at
8:30 o’clock in the morning.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, (for Medina, Misamis Oriental),


Philippines. June 9, 2014.

CAIÑA CAIÑA SABIO LAW OFFICE


Counsel for Plaintiff
2/F Ligan Building
188 Lapasan Highway
Lapasan, Cagayan de Oro City

MERLIN P. CAIÑA
Counsel for the Petitioners
1150 Camama-an, Cagayan de Oro City
IBP (OR) 945269 ; 01.2.2014,CDOC
PTR No.2504591 ; 01.8.2014,CDOC
TIN NO. 114-722-311 ; Roll No. 24443
MCLE Compliance No. IV-
0007735,9.11.2012

96 | P a g e
Notice of Hearing
Hon. Clerk of Court
RTC Br. 26 Medina,
Misamis Oriental

Kindly, take notice that the above-entitled motion be


submitted to the Honorable Court immediately upon receipt t
hereof, sans oral arguments.

MERLIN P. CAIÑA

Explanation and Proof of Service

Copy of the foregoing motion was served to Atty.


Michael Roa and Atty. Antonio Amarga by registered mail
and personal delivery respectively.

MERLIN P. CAIÑA

Copy furnished:

Michael Roa
Balingasag, Misamis Oriental
Registry receipt No. _________date: ___________

Atty. Antonio Amarga


#16, Pabayo Street
Cagayan de Oro City
Personal Service _________date: ___________

97 | P a g e
Republic of the Philippines
MUNICIPAL TRIAL COURT IN CITIES
12TH Judicial Region
Branch 2
Iligan City

PEOPLE OF THE PHILIPPINES, CRIM. CASE NOS. 10-348;


10-349; 10-350; 10-351 10-
Plaintiff, 352; 10-353;

- Versus -

RIC
ARDO SANCHEZ,
FOR: VIOLATION OF BATAS
Accused. PAMBANSA BLG. 22
x- - - - - - - - - - - - -- - - /

REJOINDER TO REPLY

98 | P a g e
Accused, by counsel to the Honorable Court most
respectfully submits Rejoinder to the Reply of the
prosecution which was received on 30 May 2014 and alleges,
THAT;

With due respect,

RE: Inadmissibility of Affidavit-Complaint of Lalit K. Sehgal


(EXHS. “A” to “A-9”, Prosecution)

The cases of Spouses Eugene L. Lim and Constancia A.


Lim, vs. The Court of Appeals Mindanao Station, et. Al., G.R
No. 192615 and Cagayan Valley Corporation vs.
Commissioner of Internal Revenue, (G.R. No. 151413,) are
not applicable in the instant cases since the factual setting
of the same are different in relation to the above entitled
cases.

Aside from the foregoing, Lalit K. Sehgal has never


been presented as a witness in the above entitled cases by
the prosecution wherein the accused was given the
opportunity in confronting him which is the interest of
the constitutional right to due process (Sec. 14, Art. III,
Philippine Constitution)

RE: Inadmissibility of (Exhs.”W”, “W-1”, W-2” & “X”)

In the formal offer of the prosecution’s exhibits herein


were never mentioned and the record will bear us out. If the
same exhibits ever exist this is not the proper time to have
it but probably in the rebuttal.

WHEREFORE, it is most respectfully prayed of the


Honorable Court that the herein Rejoinder be NOTED.
Consequently, to order the denial admissions of the
subject exhibits.

Other just equitable reliefs are likewise prayed for.

Cagayan de Oro City, Philippines. June 2, 2014

MERLIN P. CAIÑA
Counsel for the Accused
1150 Camama-an, Cagayan de Oro City

99 | P a g e
IBP (OR) 945269 ; 01.2.2014,CDOC
PTR No.2504591 ; 01.8.2014,CDOC
TIN NO. 114-722-311 ; Roll No. 24443
MCLE Compliance No. IV-0007735,9.11.2012

CERTIFICATION

I HEREBY CERTIFY, that copy of this Rejoinder is


furnished to Atty. Rex Distor Calmerin thru registered mail
due to distance.
MERLIN T. CAIÑA

Copy furnished:

Atty. Rex Distor Calmerin


#14 Purok Maligaya, Carbide Village
Brgy. Tubod, Iligan City

RR# ___________ date __________

100 | P a g e
MOTION FOR EXTENSION OF TIME

Plaintiff, by counsel unto the Honorable Court most


respectfully states, to wit;

That per Order of the Honorable Court dated November


24, 2008 and which was received by the undersigned
counsel on December 22, 2008, parties are directed to
submit their respective Position Papers within ten (10) days
from receipt of the said Order. However, due to the long
holidays in celebration of the yuletide season and new year,
undersigned counsel was not able to promptly attend and
comply with the Order of the Honorable Court.
Due to this predicament the undersigned respectfully
moves for an extension of ten (10) days from January 2,

101 | P a g e
2009 within which to file its Position Paper which is on or
before January 12, 2009.
That instant motion is filed in good faith and never
intended to delay the proceedings of the Honorable Court;

Wherefore premises considered it is most respectfully


prayed unto the Honorable Court that an extension of ten
(10) days be granted and plaintiffs be given until January
12, 2009 within which to file its Position Paper.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, (for Jasaan, Misamis Oriental),


Philippines. January 5, 2009.
CAIÑA CAIÑA SABIO LAW OFFICE
Counsel for Plaintiff
2/F Ligan Building
188 Lapasan Highway
Lapasan, Cagayan de Oro City

Sylvan Gerald L. Sabio


IBP No. 749177, Jan. 05, 2009
PTR No. 1782229 A, Jan. 05, 2009
TIN 178-265-979; Roll No. 45542
Cagayan de Oro City
MCLE Compliance No. II-0010912;
08.19.2008

Notice of Hearing
Hon. Clerk of Court
5th MCTC Jasaan-Claveria

Atty. Hilarion Jonathan G. Maagad


Counsel for Defendants

Greetings!!

The undersigned will submit the foregoing motion for the


resolution and approval of the Honorable Court immediately
upon receipts sans oral arguments and appearances of
parties.

Sylvan Gerald L. Sabio

102 | P a g e
Explanation and Proof of Service

Copy of the foregoing pleading was served to Atty. Hilarion


Jonathan G. Maagad, by registered mail, due to distance
that renders personal service impossible.

Sylvan Gerald L. Sabio

Copy furnished:

Atty. Hilarion Jonathan G. Maagad


Public Attorney’s Office
Hall of Justice
Cagayan de Oro City
Registry receipt No. _________date: ___________

Republic of the Philippines


SUPREME COURT
10th Judicial Region
5th Municipal Circuit Trial Court of Jasaan-Claveria
Jasaan, Misamis Oriental

RURAL BANK OF TALISAYAN, Civil Case No. 585


(Mis. Or.), Inc. Jasaan
Branch, as represented by
Ms. Menchu Cardinales, as
Branch Manager,
Plaintiff,

-vs-
FOR: COLLECTION OF SUM
SPS. EMILIO and MEILEN B. OF MONEY
FRANCO, ODHELIA TABACON
and FELOMINA ANO-OS,
Defendants
x- - - - - - - - - - - - - - - - - -
- /

MOTION FOR EXTENSION OF TIME

Plaintiff, by counsel unto the Honorable Court most


respectfully states, to wit;

103 | P a g e
That per Order of the Honorable Court dated November
24, 2008 and which was received by the undersigned
counsel on December 22, 2008, parties are directed to
submit their respective Position Papers within ten (10) days
from receipt of the said Order. However, due to the long
holidays in celebration of the yuletide season and new year,
undersigned counsel was not able to promptly attend and
comply with the Order of the Honorable Court.
Due to this predicament the undersigned respectfully
moves for an extension of ten (10) days from January 2,
2009 within which to file its Position Paper which is on or
before January 12, 2009.
That instant motion is filed in good faith and never
intended to delay the proceedings of the Honorable Court;

Wherefore premises considered it is most respectfully


prayed unto the Honorable Court that an extension of ten
(10) days be granted and plaintiffs be given until January
12, 2009 within which to file its Position Paper.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, (for Jasaan, Misamis Oriental),


Philippines. January 5, 2009.
CAIÑA CAIÑA SABIO LAW OFFICE
Counsel for Plaintiff
2/F Ligan Building
188 Lapasan Highway
Lapasan, Cagayan de Oro City

Sylvan Gerald L. Sabio


IBP No. 749177, Jan. 05, 2009
PTR No. 1782229 A, Jan. 05, 2009
TIN 178-265-979; Roll No. 45542
Cagayan de Oro City
MCLE Compliance No. II-0010912;
08.19.2008

Notice of Hearing
Hon. Clerk of Court
5th MCTC Jasaan-Claveria

Atty. Hilarion Jonathan G. Maagad


Counsel for Defendants

104 | P a g e
Greetings!!

The undersigned will submit the foregoing motion for the


resolution and approval of the Honorable Court immediately
upon receipts sans oral arguments and appearances of
parties.

Sylvan Gerald L. Sabio

Explanation and Proof of Service

Copy of the foregoing pleading was served to Atty. Hilarion


Jonathan G. Maagad, by registered mail, due to distance
that renders personal service impossible.

Sylvan Gerald L. Sabio

Copy furnished:

Atty. Hilarion Jonathan G. Maagad


Public Attorney’s Office
Hall of Justice
Cagayan de Oro City
Registry receipt No. _________date: ___________

Republic of the Philippines


REGIONAL TRIAL COURT
10th Judicial Region
Branch 11
Manolo Fortich, Bukidnon

ANILO SALAZAR, et. al., Civil Case No. 10-12-71

105 | P a g e
Plaintiffs,

-vs-

HEIRS OF LUCIO BALATERO, FOR: Partition, etc.


et. al.,
Defendants
x- - - - - - - - - - - - - - - - - -
- /

MOTION FOR EXTENSION OF TIME

Defendants, except Vicente Villaflor, by counsel unto


the Honorable Court most respectfully states, to wit;

That on December 6, 2010 defendants received copy of


a summons with attached complaint, hence, they have until
December 21, 2010 to file answer;

That the services of the undersigned counsel was just


engaged today and he needs more time to intelligently study
the case, gather vital documents and to prepare the answer;

That the undersigned begs the compassionate heart of


the Honorable Court that he be given an extension of Thirty
(30) days from December 21, 2010 within which to file the
required answer;

That this motion is filed in good faith and never


intended to delay the proceedings of the Honorable Court;

Wherefore premises considered it is most respectfully


prayed unto the Honorable Court that the undersigned
counsel be given an extension of THIRTY (30) DAYS from
December 21, 2010 within which to file answer.

Other relief and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City (for Manolo Fortich, Bukidnon),


Philippines. December 17, 2010.

106 | P a g e
CAIÑA CAIÑA SABIO LAW OFFICE
Counsel for defendants (except Vicente
Villaflores)
2/F Ligan Building
188 Lapasan Highway
Lapasan, Cagayan de Oro City

CHUBASCO CENEN T. CAIÑA


IBP. No. 798795, November 30, 2010
(CDO)
PTR No. 214765 A; December 14, 2010
(CDO)
MCLE Compliance No. III-0001061; 11-
6-08
Roll No. 41416 (May 7, 1997)
TIN No. 189-723-311

SYLVAN GERALD L. SABIO


IBP No. 749631, January 4, 2010 (CDO)
PTR No. 1889202 A, January 4, 2010
(CDO)
TIN 178-265-979; Roll No. 45542
All issued in Cagayan de Oro City
MCLE Compliance No. II-0010912;
08.19.2008

Notice of Hearing

Hon. Branch Clerk of Court


RTC Br. 11
Manolo Fortich, Bukidnon

Atty. Eliud T. Pailagao, Jr.,

Greetings!

Please take notice that the undersigned counsel will submit


the foregoing motion for the resolution and approval of the
Honorable Court immediately upon receipt sans oral
argument and appearances of parties.

107 | P a g e
Sylvan Gerald L. Sabio

Explanation and Proof of Service

Copy of the foregoing motion was served to Atty. Eliud T.


Pailagao, Jr. by registered mail due to personnel constrain
that renders personal service impractical and inconvenient.

Sylvan Gerald L. Sabio

Copy furnished by registered mail

Atty. Eliud T. Pailagao, Jr.


Door # 9, Desmark Arcade
Guillermo-Hayes Street
Cagayan de Oro City
Registered mail ____________ date: _________

108 | P a g e
ATTY. SAMINA MACABANDO USMAN
Asst. Prosecutor

ATTY. PALMER P. PALAMINE


Counsel for Private Offended Party/Private Prosecutor

ATTY. JUAN S. ROA


Counsel for Private Offended Party/Private Prosecutor

109 | P a g e
ATTY. CASIANO A. GAMOTIN, JR.
Counsel for Accused Queency Gonzales

Greetings!

The undersigned will submit the foregoing motion for the


resolution and approval of the Honorable Court immediately
upon receipt sans oral arguments and appearances of
parties.

Sylvan Gerald L. Sabio

Copy furnished by personal service:

Asst. Prosecutor Atty. Samina Macabando Usman


Office of the City Prosecutor
Hall of Justice
Cagayan de Oro City
Received by: ____________ date: ___________

Atty. Lino Juan S. Roa


DE LA ROSA NAGTALON GOMOS PARTNERS AND
ASSOCIATES
3RD Level-Paragon Office Suites,
R.N. Pelaez Blvd. Cor. National Highway,
Kauswagan, 9000 Cagayan de Oro City
Received by: ____________ date: ___________

Atty. Palmer P. Palamine


Palamine and Pacana Law Office
Rm. 204 R.T. de Leon III Building
Pabayo/Pacana St., Cagayan de Oro City

Sylvan Gerald L. Sabio


IBP No. 749177, Jan. 05, 2009 (CDO)
PTR No. 1782229 A, Jan. 05, 2009
(CDO)
TIN 178-265-979; Roll No. 45542
Cagayan de Oro City

110 | P a g e
MCLE Compliance No. II-0010912;
08.19.2008

starting December 21, 2010

per Order of the Honorable Court dated November 24, 2008


and which was received by the undersigned counsel on
December 22, 2008, parties are directed to submit their
respective Position Papers within ten (10) days from receipt
of the said Order. However, due to the long holidays in
celebration of the yuletide season and new year,
undersigned counsel was not able to promptly attend and
comply with the Order of the Honorable Court.
Due to this predicament the undersigned respectfully
moves for an extension of ten (10) days from January 2,
2009 within which to file its Position Paper which is on or
before January 12, 2009.
That instant motion is filed in good faith and never
intended to delay the proceedings of the Honorable Court;

Wherefore premises considered it is most respectfully


prayed unto the Honorable Court that an extension of ten
(10) days be granted and plaintiffs be given until January
12, 2009 within which to file its Position Paper.

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, (for Jasaan, Misamis Oriental),


Philippines. January 5, 2009.
CAIÑA CAIÑA SABIO LAW OFFICE
Counsel for Plaintiff
2/F Ligan Building
188 Lapasan Highway
Lapasan, Cagayan de Oro City

Sylvan Gerald L. Sabio


IBP No. 749177, Jan. 05, 2009
PTR No. 1782229 A, Jan. 05, 2009
TIN 178-265-979; Roll No. 45542
Cagayan de Oro City
MCLE Compliance No. II-0010912;
08.19.2008

111 | P a g e
Notice of Hearing
Hon. Clerk of Court
5th MCTC Jasaan-Claveria

Atty. Hilarion Jonathan G. Maagad


Counsel for Defendants

Greetings!!

The undersigned will submit the foregoing motion for the


resolution and approval of the Honorable Court immediately
upon receipts sans oral arguments and appearances of
parties.

Sylvan Gerald L. Sabio

Explanation and Proof of Service

Copy of the foregoing pleading was served to Atty. Hilarion


Jonathan G. Maagad, by registered mail, due to distance
that renders personal service impossible.

Sylvan Gerald L. Sabio

Copy furnished:

Atty. Hilarion Jonathan G. Maagad


Public Attorney’s Office
Hall of Justice
Cagayan de Oro City
Registry receipt No. _________date: ___________

112 | P a g e
113 | P a g e
Republic of the Philippines
SUPREME COURT
10th Judicial Region
6th Municipal Circuit Trial Court of Tagoloan-Villanueva
Tagoloan, Misamis Oriental

People of the Philippines, Crim. Case No. 08-6969


-plaintiff

-vs-

Celeste Dacoroon, FOR: Grave Threats


-accused
x- - - - - - - - - - - - - - - - - -
- /

URGENT MOTION TO CANCEL NOVEMBER 13, 2009


HEARING

Accused by counsel unto the Honorable Court most


respectfully states, to wit;

That the above-entitled is set for trial on November 13,


2009 at 8:30 o’clock in the morning, however on the said

114 | P a g e
time and date the undersigned counsel is committed to
appear before the Regional Trial Court Branch 40, Cagayan
de Oro City in the case of Pp vs. Roland Sabio, for Violation
of Dangerous Drugs Law and the setting of the hearing was
set long before the setting of the hearing of the above
entitle d case. The undersigned counsel thus constrain to
cancel the hearing on November 13, 2009 and the same be
reset of November 17, 2009 at 8:30 o’clock in the morning;

That the instant motion is filed in good faith and never


intended to delay the proceedings of the Honorable Court;

Wherefore premises considered it is most respectfully


prayted unto the Honorable Court that the November 13,
2009 hearing be cancelled due to conflict of schedule and
the same be reset to November 17, 2009 at 8:30 o’clock in
the morning;

Other reliefs and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, (for Tagoloan, Misamis Oriental),


November 10, 2009.

CAIÑA CAIÑA SABIO LAW OFFICE


Counsel for accused
2/F Ligan Building
188 Lapasan Highway
Lapasan, Cagayan de Oro City

Sylvan Gerald L. Sabio


IBP No. 749177, Jan. 05, 2009
PTR No. 1782229 A, Jan. 05, 2009
TIN 178-265-979; Roll No. 45542
Cagayan de Oro City
MCLE Compliance No. II-0010912;
08.19.2008

Notice of Hearing
Hon. Clerk of Court
6th MCTC Tagoloan-Villanueva
Tagoloan, Misamis Oriental

115 | P a g e
Atty. FG Bade

Chief of Police
Tagoloan Police Station

Greetings!!

The undersigned will submit the foregoing motion for the


resolution and approval of the Honorable Court immediately
upon receipts sans oral arguments and appearances of
parties.

Sylvan Gerald L. Sabio

Copy furnished by registered mail:

Chief of Police
Tagoloan Police Station
Tagoloan, Misamis Oriental
Registry receipt no. ___________ date: __________

Copy furnished personal service

Atty. Francisco G. Bade


Pabayo-Gomez Street
Cagayan de Oro City

116 | P a g e
Atty. Hilarion Jonathan G. Maagad
Public Attorney’s Office
Hall of Justice
Cagayan de Oro City
Registry receipt No. _________date: ___________

above entitled

117 | P a g e
Republic of the Philippines
SUPREME COURT
MUNICIPAL TRIAL COURT IN CITIES
Branch 2
Iligan City

People of the Philippines Criminal Case Nos. 10-348,


Plaintiff, 10-349, 10-350,10-351, 10-
352, 10-353, 10-354
-versus-

Ricardo Sanchez,
Accused.
x-----------------------------x FOR: VIOLATION OF B.P 22

MOTION FOR POSTPONEMENT

Undersigned, counsel for the accused of the above-


entitled cases, unto this Honorable Court most respectfully
moves, THUS:

1. The above-entitled cases are scheduled for


arraignment of the accused on September 21, 2010 at 2:00
o’clock in the afternoon.

118 | P a g e
2. However, due to sudden twist of events, the accused
could not possibly return from Legaspi City, Bicol attending
to an equally important business like the instant cases
thereat.

3. In the same manner, undersigned has to be in


Medina, Misamis Oriental due to an important case wherein
a member of his family named Manuel Ferdinand Lim is
involved.

4. This motion is never intended for delay but for


reasons beyond the control of the undersigned and the
accused.

WHEREFORE, it is most respectfully prayed of this


Honorable Court that the arraignment of the accused set on
September 21, 2010 be cancelled and the same be reset to
October 26, 2010 at 2:00 o’clock in the afternoon.

Other relief and remedies just and equitable under the


premises are likewise prayed for.

Cagayan de Oro City, Philippines. September 14, 2010.

MERLIN P. CAIÑA
Counsel for the Accused
Roll No. 24443
IBP (OR) No. 749641, 01.04.2010, CDOC-MIS. OR.
CHAPTER
PTR No. 1889272-A, 01.04.2010
TIN No. 114-722-311
MCLE Compliance No. 1-0013911
MCLE Compliance No. II-0011165
MCLE Compliance No. III-0001062, 11.06.2009

Notice of Hearing
Hon. Clerk of Court
MTCC Branch 2

Office of the City Public Prosecutor


Iligan City

119 | P a g e
Greetings!!

The undersigned will submit the foregoing motion for the


resolution and approval of the Honorable Court immediately
upon receipt sans oral arguments and appearance of parties.

Merlin P. Caiña

Explanation and Proof of Service

Copy of the foregoing pleading was served to the City Public


Prosecutor by registered mail due to distance that renders
personal service impractical and inconvenient.

Merlin P. Caiña

Copy furnished by registered mail:

Office of the City Public Prosecutor


Iligan City
Registry Receipt No. ____________;
Date: ____________

120 | P a g e