Petitioners,: Manifestation and Motion For Extension To Submit Comment

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Republic of the Philippines

Court of Appeals
Cebu City
TWENTIETH DIVISION

BOBBY CASIMERO, RAMIL


UNTALAN, SPOUSES NESTOR
MAGBANUA, SPOUSES WILMA &
DAMIANO HANSULI, DIONITO
DE SULLAN, HELEN SUALOG,
and CLARA SAAVEDRA
Petitioners,

-versus- CA-G.R. SP NO. 12197

HON. JUDGE NELSON


BARTOLOME, DEPUTY SHERIFF
DANILO YAP, and THE HEIRS
OF PABLITO SUALOG,
Represented in this suit by their
ATTORNEY-IN-FACT CLARO P.
SUALOG,
Respondents.
x-------------------------------------------------x

MANIFESTATION AND
MOTION FOR EXTENSION TO SUBMIT COMMENT

PRIVATE RESPONDENTS THE HEIRS OF PABLITO SUALOG, by


counsel, unto this Honorable Court, respectfully avers that:

1. On July 14, 2020, private respondent received the Notice of


Resolution with a copy of the Resolution dated March 4, 2020.

2. Likewise, on the even date, private respondent received the copy of


the Resolution dated March 4, 2020 directing private respondents to file a
COMMENT on the Petition (not a Motion to Dismiss) within ten (10) days from
notice.

3. That, the undersigned counsel, however, most respectfully manifests


before this Honorable Court that the undersigned counsel has not been furnished
by petitioners a copy of the Petition.

4. That when the undersigned inquired from its client thru the Attorney-
In-Fact Claro P. Sualog, it was informed that the copy of the petition was sent to
him and not to the office of the undersigned counsel.
5. That considering that the Attorney-In-Fact resides in Buruanga,
Aklan, which is the farthest municipality in Aklan, and with the present pandemic,
the undersigned is unsure of the length of time the mail containing the copy of the
Petition sent by the Attorney-In-Fact Claro P. Sualog will reach it office.

6. As such, the undersigned counsel is constrained to request for an


additional period of ten (10) days from today or until August 1, 2020
within which to submit Respondent's Comment.

 7. Likewise, the undersigned counsel also moves that petitioners be


directed to furnish private respondents of copies of their pleadings and notices to
the office of the undersigned counsel at Unit 201 Doña Eusebia Building, 0611
Quirino Avenue, San Dionisio, Parañaque City

7. This Motion is not intended for delay but solely due to the foregoing


reasons.

PRAYER

WHEREFORE, PRIVATE RESPONDENTS THE HEIRS OF PABLITO


SUALOG, most respectfully pray of this Honorable Court that:

1. This Manifestation be noted;


2. Direct petitioners to furnish private respondents of copies of their
pleadings and notices to the office of the undersigned counsel at Unit
201 Doña Eusebia Building, 0611 Quirino Avenue, San Dionisio,
Parañaque City
3. Private Respondents be given an additional period of ten (10) days
from today or until August 1, 2020 within which to submit Comment on the
Petition.

Other reliefs just and equitable are likewise prayed for.

Paranaque City, July 22, 2020.

COS GUEVARRA & ASSOCIATES LAW OFFICES


Unit 201 Doña Eusebia Building
0611 Quirino Avenue, San Dionisio, Parañaque City
Telefax No. 825-9918/ 09989984009

By:

ATTY. MELANIE OBRIQUE-GUEVARRA


Counsel for Private Respondents
IBP No. 070285; 01-25-2019; Pasig City
PTR No. 2286254:01-24-2020; Parañaque City
Roll No. 56511
MCLE Compliance No. VI-0014042

NOTICE OF HEARING

Court of Appeals
Cebu City
Twentieth Division

Atty. Jerome C. Padios


Unit 1, 3rd Floor, Rosary Building, Iznart Street, Iloilo City
Mobile No. 09177937367

Please submit this motion for the consideration of the Honorable Court
without need for further hearing in view of the above circumstances.

EXPLANATION

A copy of this manifestation and motion was sent via registered mail/LBC
due to the distance, lack of time, and unavailability of office personnel.

ATTY. MELANIE OBRIQUE-GUEVARRA

Copy Furnished:

PADIOS APLASCA MOMBAY EDANG LAGANCE LAW OFFICE


Atty. Jerome C. Padios
Unit 1, 3rd Floor, Rosary Building, Iznart Street, Iloilo City
Mobile No. 0917793736

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