The petitioners filed a second motion for extension of time to file a reply to the respondent's comment on the petition for review on certiorari. They are requesting a 10-day extension until August 18, 2014 due to the counsel's health issues of diabetes and high blood pressure that prevented him from preparing the reply on time. The affidavit of service and filing details the service of the motion by registered mail to the relevant parties and filing with the Supreme Court by the same means.
The petitioners filed a second motion for extension of time to file a reply to the respondent's comment on the petition for review on certiorari. They are requesting a 10-day extension until August 18, 2014 due to the counsel's health issues of diabetes and high blood pressure that prevented him from preparing the reply on time. The affidavit of service and filing details the service of the motion by registered mail to the relevant parties and filing with the Supreme Court by the same means.
The petitioners filed a second motion for extension of time to file a reply to the respondent's comment on the petition for review on certiorari. They are requesting a 10-day extension until August 18, 2014 due to the counsel's health issues of diabetes and high blood pressure that prevented him from preparing the reply on time. The affidavit of service and filing details the service of the motion by registered mail to the relevant parties and filing with the Supreme Court by the same means.
RE: IN THE MATTER OF PETITION FOR CANCELLATION OF THE CERTIFICATE OF ANCESTRAL LAND TITLE OF MAXIMO EDWIN BUGNAY, SR.
GABRIEL B. DICLAS, ANTONIA S. DIANSON, CARLOS ANSIS, JOSEPH A. SOYPAAJN, CORAZON SOYPAAN, RITA BIADOR, MERTO SALDET, IMELDA INGOSAN, MYRNA BASANES, GRACE SOLANO, MARCELO CATANES, VALENTINO C. SEC-OPEN, DIXSON S. ANCHES, CARLOS ANCHES, JR., and FRANCIS QUE, JR., Petitioners, GR No. 209691 -versus-
SECOND MOTION FOR EXTENSION OF TIME TO FILE REPLY (TO THE RESPONDENTS COMMENT ON THE PETITION FOR REVIEW ON CERTIORARI)
PETITIONERS, through counsel, to the Honorable Tribunal, respectfully pray for another extension of TEN (10) DAYS to file their Reply to the Comment of Respondent on the Petition for Review on Certiorari, and they most respectfully manifest:
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1. That on July 14, 2014, undersigned counsel received a NOTICE dated June 4, 2014 and ordering the Petitioners to file their Reply on the Respondents Comment;
2. That Petitioners were given TEN (10) DAYS or until July 24, 2014, from receipt of the Notice, to file the Reply. On July 22, 2014, undersigned counsel filed a Motion for Extension of Time to File Reply praying for an extension of FIFTEEN (15) DAYS counted from July 25, 2014. However, undersigned counsel mistakenly stated that the last day of the extension is AUGUST 9, 2014, it should be AUGUST 8, 2014; hence, undersigned counsel is asking for apology for that inadvertence;
3. That the undersigned counsel, with profuse apology, was not able to prepare the Reply within the prayed fifteen (15) days extension which will expire on August 8, 2014;
4. That the undersigned counsel was stricken with diabetes and high blood pressure and took time to convalescence and cannot prepare the reply in accordance with oath of lawyers to serve with utmost best for his clients and the spirit of the law;
5. That this motion is not intended to cause undue delay in the disposition of the case and the respondent will not in any way be prejudiced by a reasonable extension of time being sought by the petitioners within which to file their aforesaid Reply.
WHEREFORE, petitioners respectfully pray of the Honorable Tribunal to grant them, in the interest of justice and equity, another extension of TEN (10) DAYS counted from August 9, 2014 or until August 18, 2014, within which to file their Reply.
They further pray for such other remedies just and equitable in the premises.
Baguio City for Manila, Philippines, August 5, 2014.
MODESTO T. ANDONG 3
Counsel for the Petitioners Rm. 13-B, 2 nd floor, Old Market Bldg., Magsaysay Ave., Baguio City ROLL No. 31289, 5.15.81, Manila PTR No. 1575953/01-03-14/Baguio City IBP No. 937789/12-12-13/Baguio-Benguet Chapter MCLE COMPLIANCE No. V-0002709/July 3, 2014
NOTICE
ATTY. WILFREDO V. LAPITAN DIVISION CLERK OF COURT THIRD DIVISION SUPREME COURT, MANILA
DEAR SIR:
GREETINGS!
Please submit the foregoing MOTION for the kind consideration and approval of the Honorable Division.
Thank you.
MODESTO T. ANDONG Counsel for the Petitioners
REPUBLIC OF THE PHILIPPINES) DONE: In the City of Baguio ) SS.
AFFIDAVIT OF SERVICE AND FILING
I, MODESTO T. ANDONG, as counsel for petitioners in the above-entitled case and with office address at Rm. 13-B, 2 nd floor, Old Market Bldg., Magsaysay Avenue, Baguio City, under an oath, do hereby depose and state that:
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PROOF OF SERVICE. On August 5, 2014 I caused to serve by registered mail a copy of the foregoing Motion on Atty. Mathew L. Dati, counsel for the respondent, with office address at ALS Building, Capitol Drive, Km. 6, La Trinidad, Benguet, under Registry Receipt No. _________, which is hereto attached on the first original copy.
On August 5, 2014, I served a copy of this Motion on the Honorable Court of Appeals at Manila, by registered mail under Registry Receipt No. ____________, which registry receipts are hereto attached on the first original copy.
Also on August 5, 2014, I served a copy of this Motion on the Honorable National Commission on Indigenous Peoples, 2 nd Floor Dela Merced Bldg., Quezon Ave., cor. West Ave., Quezon City, by registered mail under Registry Receipt No. ____________, which registry receipts are hereto attached on the first original copy
PROOF OF FILING. Likewise, on August 5, 2014, I filed by registered mail the required number of five (5) copies of the foregoing motion, and a soft copy of the same. In PDF format, by compact disc (CD), to the Honorable Supreme Court, through its Clerk of Court, in accordance with Section 5 (a) of AM No. 11-9-4 SC, under Registry Receipt No. ____________. The motion in five (5) copies, and a soft copy of the same, in PDF format, by compact disc (CD), are enclosed in a sealed envelope duly addressed to the Clerk of Court of the Honorable Supreme Court, with postage fully prepaid and deposited with the Baguio City Post Office, with instructions to the postmaster to return the mail matter to the sender after ten (10) days if not delivered, in accordance with Section 12, Rule 13, of the 1997 Rules of Civil Procedure.
EXPLANATION. The filing of this motion to the Honorable Supreme Court and service to Atty. Mathew L. Dati, Honorable Court of Appeals and Honorable National Commission on Indigenous Peoples by registered mail was resorted to by the petitioners because of constraints of distance and time, rendering of personal service and personal filing impracticable.
IN WITNESS WHEREOF, I have hereunto set my hand this 5 th day of August, 2014 at Baguio City, Philippines. 5
MODESTO T. ANDONG Affiant
SUBSCRIBED AND SWORN to before me this 5 th day of August, 2014 at Baguio City, Philippines, affiant exhibiting to me his GSIS identification card bearing serial number 4404- 5277-2963-9506 issued on March 3, 2006 by the GSIS Baguio City Branch Office.
Doc. No. ________; Page No. ________; Book No. ________; Series of 2014.