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REPUBLIC OF THE PHILIPPINES

SUPREME COURT
MANILA

PEOPLE OF THE PHILIPPINES,


Plaintiff-Respondent,

- versus - G.R. No. 123456


(CA-G.R. CR No. 45667,
People of the Philippines v.
Juan A. Dela Cruz)

FOR: Petition for Review


on Certiorari under Rule
45 of the Rules of Court
JUAN A. DELA CRUZ,
Accused- Petitioner.
x ------------------------------------ x

SECOND MOTION FOR EXTENSION OF TIME


TO FILE PETITION FOR REVIEW

ACCUSED-PETITIONER JUAN A. DELA CRUZ, by counsel, to the


Honorable Court, respectfully states:

1. On 10 February 2017, accused-appellant, filed a timely


motion for extension of time to file his petition for review asking for
fifteen (15) days or until 26 February 2017 within which to file his
petition for review.

2. Unfortunately, such period proved to be insufficient for the


undersigned new counsel to review and study the entire records of the
case from the trial court up to the appeal to the Court of Appeals.

3. Thus, undersigned counsel, begs the kindest indulgence of


the Honorable Court to grant her another fifteen (15) days or until 13
March 2017 to file the required petition pursuant to Section 2, Rule 45
of the Rules of Court.

4. This motion is not intended to delay the proceedings of the


instant case but is being filed in good faith solely for the afore-stated
reasons.

PRAYER

WHEREFORE, it is respectfully prayed that petitioner be granted


an another extension of fifteen (15) days from 26 February 2017, or
until 13 March 2017, within which to file the intended petition.

Quezon City for the City of Manila, 26 February 2017.


SECOND MOTION FOR EXTENSION OF TIME TO FILE PETITION

People v. Juan dela Cruz


G.R. No. 123456
x ----------------------------------------------------------------- x

THE LAW OFFICE OF


ATTY. JOSE A. DELA CRUZ
5555555 Kamuning Road,
1103 Quezon City

By:

JOSE A. DELA CRUZ


Roll No. 00000
IBP O.R. No. 00000001, 1.26.2017, Q. C.
PTR No. 00000011, 1.25.2017, Q.C.
MCLE Compliance No. IV 0000002

JUAN B. DELA CRUZ


Roll No. 00001
IBP NO. 0000002, Jan. 14, 2017, Manila
PTR NO. 0000002, Feb. 13, 2017, Manila
MCLE Compliance No. V-0000003

Copy furnished:
COURT OF APPEALS (by personal service)
(16th Division), City of Manila

OFFICE OF THE SOLICITOR GENERAL (by reg.mail)


134 Amorsolo Street, Legaspi Village,
1229 Makati City

EXPLANATION
(Pursuant to Section 11, Rule 13 of the 1997 Rules of Civil Procedure)

Copies of this Second Motion for Extension of Time to File


Petition for Review were furnished the foregoing recipients by
registered mail due to distance and the limited messengerial facility to
effect personal service.

CRISTINA B. BUENDIA
SECOND MOTION FOR EXTENSION OF TIME TO FILE PETITION

People v. Juan dela Cruz


G.R. No. 123456
x ----------------------------------------------------------------- x

REPUBLIC OF THE PHILIPPINES )


CITY OF MANILA ____________ ) S.S.
x --------------------x

AFFIDAVIT OF SERVICE

I, JUAN A. TAMAD, of legal age, Filipino, married, and postal


address at 12345 Alcalde Street, Gagalangin, Tondo, Manila, state
under oath:

On 27 February 2017, I served the foregoing Second Motion for


Extension in G.R. No. 123456 entitled People of the Philippines v. Juan
A. Dela Cruz pursuant to Sections 3, 4, 5, 10, 11 and 13, Rule 13 of
the 1997 Rules of Civil Procedure by registered mail to the following:

OFFICE OF THE SOLICITOR GENERAL


134 Amorsolo Street, Legaspi Village,
Makati City

by depositing copies with the ____________ Post Office as evidenced


by Registry Receipt No. ________________ attached hereto, and with
instructions to the postmaster to return the mail to the sender after
ten (10) days if undelivered.

27 February 2017 at City of Manila.

JUAN A. TAMAD
Affiant

SUBSCRIBED AND SWORN TO before me on ______________


at ___________________, affiant exhibiting to me his SSS I.D. No.
01-23456781-9 valid permanently.

Doc. No. _____


Page No. _____
Book No. _____
Series of 2017