Republic of the Philippines
MUNICIPAL TRIAL COURT IN CITIES
Fifth Judicial Region
Branch 2
Sorsogon City
PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 2018-1589
Plaintiff, FOR: ESTAFA
-vs.-
ERNESTO SAMONTE y
DAGŃALAN and RIZZA
MATEOS y CARO.
Accused.
X- - - - - - - - - - - - - - - - - X
URGENT MOTION TO RESET
the October 28, 2019 hearing
COMES NOW, the undersigned counsel and to this Honorable Court
most respectfully states that:
1. The hearing of this case has been set on October 28, 2019 at 8:30
o’clock in the morning;
2. However, the undersigned counsel hereby regretfully informs the
Honorable Court that he cannot attend said hearing as he will be meeting with
the rest of the entire Oropesa clan who came from the different parts of the
Country to conclude and facilitate the settlement and sale of their hereditary
property to a buyer who is scheduled to arrive from the United States of
America on that day. The negotiation, generation and sale transaction had been
made six (6) months prior to that day and it is on that day that the sale will be
concluded by, between and among the vendors and the vendees;
3. With this, the undersigned is constrained to respectfully request the
Honorable Court to reset the hearing of the instant case to another date, subject
to the availability of the Honorable Court’s calendar.
4. This motion is made in good faith and not intended to delay the
proceedings of the instant case.
PRAYER
WHEREFORE, based on the premises presented, it is most respectfully
prayed that the hearing of the instant case be reset to November 11, 2019 or to
another date, subject to the availability of the Honorable Court’s calendar.
Such other reliefs and remedies as are just and equitable under the
premises are likewise prayed for.
Sorsogon City, this 25th day of October, 2019.
CYRIL C. OROPESA
Counsel for the Accused
Rollo No. 54962
IBP No. 847640/January 2, 2014
PTR No. 147967/January 15, 2015
MCLE Compliance No. IV-0023763 UP Law Center
University of the Philippines, Diliman, Quezon City
#435 Market Site Sirangan, Sorsogon City
CP No. 09177672368/cyril_621975@[Link]
NOTICE
THE BRANCH CLERK OF COURT
MTCC- Br. 2, Sorsogon City
Sir:
GREETINGS! Please submit the foregoing MOTION TO RESET to the
Honorable Court for its consideration upon receipt hereof on October 28, 2019, at
8:30 o’clock in the morning at its Session Hall, MTCC-Branch 2, Sorsogon City, or
as soon as counsel may be heard sans any arguments.
CYRIL C. OROPESA
Counsel for the Accused
Rollo No. 54962
IBP No. 847640/January 2, 2014
PTR No. 147967/January 15, 2015
MCLE Compliance No. IV-0023763 UP Law Center
University of the Philippines, Diliman, Quezon City
#435 Market Site Sirangan, Sorsogon City
CP No. 09177672368/cyril_621975@[Link]
NOTICE
THE BRANCH CLERK OF COURT
MTCC- Br. 2, Sorsogon City
Atty. MELBERT BALICANO
Assoc. City Prosecutor
City Prosecution Office
Hall of Justice, Sorsogon City
Sir/s:
GREETINGS! PLEASE BE NOTIFIED that on October 28, 2019 at 8:30
o’clock in the morning, or as soon as counsel may be heard, the undersigned will
ask the MTCC-Branch 2, Sorsogon City to approve the foregoing Motion to
Reset from the Honorable Court, at its Session Hall, MTCC-Branch 2, Sorsogon
City, sans any argument.
CYRIL C. OROPESA
Counsel for the Accused
Rollo No. 54962
IBP No. 847640/January 2, 2014
PTR No. 147967/January 15, 2015
MCLE Compliance No. IV-0023763 UP Law Center
University of the Philippines, Diliman, Quezon City
#435 Market Site Sirangan, Sorsogon City
CP No. 09177672368/cyril_621975@[Link]
Copy Furnished:
HON. MELBERT BALICANO
Assoc. City Prosecutor
City Prosecution Office
Hall of Justice, Sorsogon City
