Republic of the Philippines

SUPREME COURT
Eighth (8th) Judicial Region
Regional Trial Court-Branch 34
Bulwagan ng Katarungan
Magsaysay Blvd., Tacloban City

JUAN de la CRUZ, CIVIL CASE No. R-TAC-17-01176-

Plaintif, CV
FOR: BREACH OF CONTRACT OF
CARRIAGE (ART. 1733 in relation
-versus- to Art 1755, etc., New Civil Code
of the Philippines) WITH
DAMAGES
PEDRO RAMOS &
VICENTE JOSE,
Defendants.
x---------------------------------------------x

MOTION FOR EXTENSION OF TIME

DEFENDANT, by the undersigned counsel, and unto this

Honorable Court, most respectfully states that:

1. Defendant engaged the services of undersigned

counsel only on March 11, 2017;

2. Defendant was served with Summons and copy of the

Complaint on February 24, 2017 and thus has until March
11, 2017 within which to submit an Answer or
Responsive Pleading;

3. However, due to the pressures of equally urgent

professional work and prior commitments, the
undersigned counsel will not be able to meet the said
deadline;
 4. As such, undersigned counsel is constrained to request
for an additional period of 15 days from today
within which to submit Defendant's Answer or
Responsive Pleading. Moreover, this additional time will
also allow the undersigned to interview the available
witness and study this case further;

5. This Motion is not intended for delay but solely

due to the foregoing reasons.

PRAYER

WHEREFORE, Defendant most respectfully prays of this

Honorable Court that he be given an additional period of 15
days from today within which to submit an Answer or other
Responsive Pleading.

Other relief just and equitable are likewise prayed for.

Tacloban City, Philippines, March 11, 2017.

ARTIKULO TRES LAW OFFICES

Corner Real St. Tacloban City
Counsel for the Defendants
By:

ATTY. ANDREA BONIFACIO

Attys. Roll No. 51444/ 5-10-06
PTR No. 9005803/1-4-16 Palo, Leyte
IBP O.R. NO. 0989528/01-04-16, Leyte Chapter
MCLE COMPLIANCE NO.: V-0004454/11-12-2014
valid until 11-12-2019

NOTICE

Atty. EMILIO B. AGUINALDO

Branch Clerk of Court
&
Atty. DONNALIZA P. SABELLANO, Atty. SUZANNE B.
IBAEZ, & Atty. JANJAN H. BERNARDO
Counsels for the Plaintiffs
Please take notice that this motion will be submitted for the
resolution of the Honorable Presiding Judge immediately
upon filing hereof sans appearance and oral arguments from
parties and counsels.

Atty. ANDREA BONIFACIO

COPY FURNISHED: By personal service

ATTY. DONNALIZA P. SABELLANO

Rm 101, 1st Floor, Law Building
DVOREF College of Law
Calanipawan Road, Brgy 96
Tacloban City

Received by: ______________________Date: __________________

ATTY. SUZANNE B. IBAEZ

Rm 101, 1st Floor, Law Building
DVOREF College of Law
Calanipawan Road, Brgy 96
Tacloban City

Received by: ______________________Date: __________________

ATTY. JANJAN H. BERNARDO

Rm 101, 1st Floor, Law Building
DVOREF College of Law
Calanipawan Road, Brgy 96
Tacloban City

Received by: ______________________Date: __________________