GUZMAN TAEDO & ACAIN LAW OFFICES

Alexander Llanes Acain, Jr. (Roll No. 42604 )

316 Mile Long Building
Amorsolo Street, Makati City
Telefax
: 812-4296
Telephone
: 894-1441
website
: www.gtalawphil.com
ATTORNEYS FOR PETITIONER
Ma. May Angelica E. Enesio

REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
BRANCH 194
PARAAQUE CITY

MA. MAY ANGELICA E. ENESIO,

Petitioner,
- versus -

JONATHAN E. FAVIS,
Respondent.

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] JDRC Case No. 15-72
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For: Declaration of
]
Nullity of Marriage
]
]
]

___________________________

EXTRAORDINARY MOTION
FOR RESETTING
[ of the April 22 hearing to 28 April 2015 ]
___________________________

PETITIONER, by the undersigned counsel, unto this

Honorable Court, most respectfully avers that:
PETITION FOR NULLITY OF MARRIAGE
Enesio vs. Favis
Page 1 of 5

1.
On 17 April 2015, Petitioner by counsel, has filed a
Motion for Reconsideration with leave of Court to accept Amended
Complaint and said Motion was set for hearing for 21 April 2015;

2.
There is a pressing personal family matter of equal
importance which requires counsel to go home to his hometown in
Molave, Zamboanga Del Sur on April 20, 2015;
3.
Counsel has already booked a plane ticket to Ozamis
City and from Ozamis City, he will proceed to his hometown in
Molave, Zamboanga Del Sur which will take an hour travel time
from Ozamis City, copy of his PAL e-ticket is hereto attached and
marked as ANNEXES A and A-1 and made integral part
hereof;
4.
In view thereof, counsel begs the indulgence of this
Honorable Court that the hearing of the Motion on 22 April 2015
be reset preferably to 28 April 2015 at 8:30 in the morning;
5.
This Motion is not intended to delay the proceedings
on this case or frustrates the ends of justice but is filed based solely
on the aforementioned reasons.

PRAYER

WHEREFORE, foregoing premises considered, it is

respectfully prayed of the Honorable Court that this Motion be
granted in the interest of substantial justice.

PETITION FOR NULLITY OF MARRIAGE

Enesio vs. Favis
Page 2 of 5

Petitioner likewise prays for such other just and equitable

relief under the prevailing circumstances.
RESPECTFULLY SUBMITTED.
Makati City for Paraaque City, 19 April 2015.

GUZMAN TAEDO & ACAIN

LAW OFFICES
Counsel for the Petitioner
316 Mile Long Bldg., Amorsolo St.
1200 Makati City

By:

ALEXANDER LLANES ACAIN, JR.

IBP No. 0981828, issued Jan 05, 2015 ZDS
PTR No. 4748619, issued Jan 05, 2015, Makati City
MCLE Compliance No. IV-0019082. April 25, 2013
Roll No. 42604

NOTICE

THE BRANCH CLERK OF COURT

RTC Branch 194
Paraaque City
PETITION FOR NULLITY OF MARRIAGE
Enesio vs. Favis
Page 3 of 5

Greetings:
Kindly submit the foregoing non-litigious Motion for
consideration of the honorable court immediately upon receipt
hereof with oral arguments.

ALEXANDER LL. ACAIN, JR.

OFFICE OF THE CITY PROSECUTOR

Paraaque City
Greetings:
Please take notice that the foreoging non-litigious Motion
will be submitted to for consideration of the Honorable Court
without oral arguments.
ALEXANDER LL. ACAIN, JR.

OFFICE OF THE SOLICITOR GENERAL

Makati City
Greetings:

PETITION FOR NULLITY OF MARRIAGE

Enesio vs. Favis
Page 4 of 5

Please take notice that the foreoging non-litigious Motion

will be submitted to for consideration of the Honorable Court
without oral arguments.

ALEXANDER LL. ACAIN, JR.

Copy furnished:

OFFICE OF THE CITY PROSECUTOR

Paraaque City

OFFICE OF THE SOLICITOR GENERAL

Makati City

MOTION
Enesio vs. Favis
Civil Case No. 15-72

PETITION FOR NULLITY OF MARRIAGE

Enesio vs. Favis
Page 5 of 5