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Republic of the Philippines


SUPREME COURT
Manila

THIRD DIVISION

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-

MAXIMO BUGNAY SR.,
Respondent.
x---------------------------------------------------x

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
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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.
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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.