Republic of the Philippines

REGIONAL TRIAL COURT

9th Judicial Region
Branch 15, Zamboanga City
PEOPLE OF THE PHILIPPINES,
Plaintiff,

Crim. Case No. 27317

-versus-

for

EARLBON RULE y ESPINAS,

Accused.
X--------------------------------------X

RAPE

EX-PARTE MOTION TO RESET HEARING

COMES NOW, Accused through undersigned Counsel and unto
this Honorable Court most respectfully manifests and states that:
1. The above-entitled case is scheduled for trial on October 10,
2016 in the morning;
2. However, without disregarding the importance of this case,
Accused is constrained to ask for the cancellation of the
scheduled hearing on account of Hearing Regional Trial
Court Branch 5, Bongao, Tawi-Tawi on October 10, 11, 12,
12, 14, 17, 18, 19, 20 and 21, 2016 all at 2:00 oclock in the
afternoon (Copy of Order Hearing R.T.C. Branch 5, Bongao,
Tawi-Tawi hereto attached as Annex A), and that the
same be reset to any available calendar date of this
Honorable Court;
3. Accused most respectfully manifests sincerity and veracity in
the relief prayed for herein and that the same is not in any
way intended to delay the proceedings hereof.
PRAYE R
WHEREFORE, it is most respectfully prayed of this Honorable
Court that the hearing scheduled on October 10, 2016 be cancelled
and that the same be reset to any available calendar date of this
Honorable Court.
Other reliefs as may be just and equitable under the premises are
likewise prayed for.

City of Zamboanga, Philippines, 5th October 2016.

GIAN PAOLO U. ENRIQUEZ

Counsel for Accused
ENRIQUEZ CAPIN GAUGANO & ASSOCIATES LAW OFFICES
2nd Floor, LDM Bldg., Pilar St., Zamboanga City
PTR No. 0933265 - 01/04/16
IBP No. 897185 - 01/04/16
at Zamboanga City
Roll No.49871-05/02/05
MCLE Compliance No. III- 0012187-04/13/10
MCLE Compliance No. IV- 0000617-11/05/10
MCLE Compliance No. V- 0002658 06/19/14

COPY FURNISHED:
Office of the City Prosecutor
Hall of Justice, Sta. Barbara
Zamboanga City

NOTICE OF HEARING
The Clerk of Court
RTC Branch 15
Hall of Justice, Sta. Barbara
Zamboanga City
Office of the City Prosecutor
Hall of Justice, Sta. Barbara,
Zamboanga City

Greetings!
Please take notice that the undersigned counsel is submitting
the foregoing Ex-Parte Motion to Reset Hearing for the consideration
and approval of the Honorable Court without need of oral argument.

GIAN PAOLO U. ENRIQUEZ