Motion
Content
Republic of the Philippines
METROPOLITAN TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
Pasay City
Branch 12
PEOPLE OF THE PHILIPPINES,
Complainant,
-versusJOCET CONSISA
RAMIREZ,
PABILONA
y
CRIMINAL CASE NO. M-QZN-1506745-CR
FOR: ATTEMPTED ESTAFA THRU
FALSIFICATION
OF
PUBLIC
DOCUMENT
Accused.
x-----------------------------x
MOTION FOR RESETTING
DEFENDANT, through the undersigned counsel and to this Honorable Court most
respectfully state that:
1. The hearing of this case has been set on 22 February 2016 at 9:00 AM in the morning;
2. However, the undersigned counsel hereby regretfully informs the Honorable Court that
she is not able to attend the said hearing due to a previous scheduled hearing on the same
date held in Tuguegarao City, Cagayan;
3. With this, the undersigned respectfully requests the Honorable Court to reset the hearing
of the instant case to 14 March 2016;
4. That the aforesaid date was agreed to by the public prosecutor, Atty. Pia Faustino;
5. This motion is made in good faith and not intended to delay the proceedings of the
Honorable Court.
WHEREFORE, based on the premises considered, it is most respectfully prayed that the
hearing of the instant case be cancelled and reset to 14 March 2016.
Other reliefs just and proper are likewise prayed for.
This is hereby submitted today, 04 February 2016, in Manila, Philippines.
PRAYER
WHEREFORE, in the interest of justice, it is respectfully prayed for that this Honorable
Court RESET the hearing scheduled on 14 March 2016, or at any date thereafter at this
Honorable Court’s convenience.
Other reliefs, just and equitable under the premises are likewise being prayed for.
Respectfully submitted. Pasay City for Manila City. 04 February 2016.
PIA FAUSTINO
Roll No. 23456
IBP No. 22345/1-3-12/Manila
PTR No. 33456/1-3-12/Manila
THE BRANCH CLERK OF COURT
Regional Trial Court
Manila City
GREETINGS:
Please take notice due to the non-litigious nature of the foregoing Motion, the same shall
be submitted by the undersigned counsel without further argument.
PIA FAUSTINO
COPY FURNISHED:
DANICA FLORICIA MAE DELGADO-TRINIDAD
Counsel for the Plaintiff
Unit 1234, 42nd Floor, One Corporate Center
Dona Julia Vargas Avenue, Corner Meralco Avenue
Ortigas Center, Pasig City
E X PLAN AT I O N
The original copy of the pleading/motion to which this explanation is attached was:
filed with this Honorable Court by registered mail;
sent to counsel for the adverse party/ies by registered mail;
Due to the following reason/s:
the distance between this Honorable Court and counsel's office which makes
personal filing of the pleading/motion impracticable;
the distance from the office of counsels for both parties which makes personal
service impracticable;
lack of office personnel to effect personal service;
time constraints.
PIA FAUSTINO
METROPOLITAN TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
Pasay City
Branch 12
PEOPLE OF THE PHILIPPINES,
Complainant,
-versusJOCET CONSISA
RAMIREZ,
PABILONA
y
CRIMINAL CASE NO. M-QZN-1506745-CR
FOR: ATTEMPTED ESTAFA THRU
FALSIFICATION
OF
PUBLIC
DOCUMENT
Accused.
x-----------------------------x
MOTION FOR RESETTING
DEFENDANT, through the undersigned counsel and to this Honorable Court most
respectfully state that:
1. The hearing of this case has been set on 22 February 2016 at 9:00 AM in the morning;
2. However, the undersigned counsel hereby regretfully informs the Honorable Court that
she is not able to attend the said hearing due to a previous scheduled hearing on the same
date held in Tuguegarao City, Cagayan;
3. With this, the undersigned respectfully requests the Honorable Court to reset the hearing
of the instant case to 14 March 2016;
4. That the aforesaid date was agreed to by the public prosecutor, Atty. Pia Faustino;
5. This motion is made in good faith and not intended to delay the proceedings of the
Honorable Court.
WHEREFORE, based on the premises considered, it is most respectfully prayed that the
hearing of the instant case be cancelled and reset to 14 March 2016.
Other reliefs just and proper are likewise prayed for.
This is hereby submitted today, 04 February 2016, in Manila, Philippines.
PRAYER
WHEREFORE, in the interest of justice, it is respectfully prayed for that this Honorable
Court RESET the hearing scheduled on 14 March 2016, or at any date thereafter at this
Honorable Court’s convenience.
Other reliefs, just and equitable under the premises are likewise being prayed for.
Respectfully submitted. Pasay City for Manila City. 04 February 2016.
PIA FAUSTINO
Roll No. 23456
IBP No. 22345/1-3-12/Manila
PTR No. 33456/1-3-12/Manila
THE BRANCH CLERK OF COURT
Regional Trial Court
Manila City
GREETINGS:
Please take notice due to the non-litigious nature of the foregoing Motion, the same shall
be submitted by the undersigned counsel without further argument.
PIA FAUSTINO
COPY FURNISHED:
DANICA FLORICIA MAE DELGADO-TRINIDAD
Counsel for the Plaintiff
Unit 1234, 42nd Floor, One Corporate Center
Dona Julia Vargas Avenue, Corner Meralco Avenue
Ortigas Center, Pasig City
E X PLAN AT I O N
The original copy of the pleading/motion to which this explanation is attached was:
filed with this Honorable Court by registered mail;
sent to counsel for the adverse party/ies by registered mail;
Due to the following reason/s:
the distance between this Honorable Court and counsel's office which makes
personal filing of the pleading/motion impracticable;
the distance from the office of counsels for both parties which makes personal
service impracticable;
lack of office personnel to effect personal service;
time constraints.
PIA FAUSTINO
