Republic of the Philippines

Province of Lanao del Norte

TH
4 MUNICIPAL CIRCUIT TRIAL COURT
MAIGO-BACOLOD-MUNAI
12th Judicial Region
Bacolod, Lanao del Norte

PEOPLE OF THE PHILIPPINES, CRIM CASE NO. 1945-N

Plaintiff,
FOR: OBSTRUCTION OF JUSTICE (Sec.
- versus - 1b, PD 1829)

P/INSP JONATHAN L. ASTILLERO,

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

PEOPLE OF THE PHILIPPINES, CRIM CASE NO. 1952-N

Plaintiff,
FOR: OBSTRUCTION OF JUSTICE (Sec.
- versus - 1b, PD 1829)

P/INSP JONATHAN L. ASTILLERO,

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

MOTION FOR EXTENSION

TO FILE MEMORANDUM

ACCUSED P/INSP JONATHAN L. ASTILLERO, through undersigned

Counsel, unto this Honorable Court most respectfully files Motion and
further avers that:

1) On 27 September 2017, Accused received an Order dated 18

September 2017 from this Honorable Court stating that "parties are
given 30 days from receipt of this order to file their respective
memorandum." Thus, Accused has until 27 October 2017 to file the
required Memorandum.

2) Counsel is saddled with numerous other equally important and

urgent legal commitments that require in-depth studies and
research and physical appearances in courts, besides being the Vice-
President of the Integrated Bar of the Philippines (IBP) – Misamis
Oriental Chapter. Counsel thus begs the indulgence and
understanding of this Honorable Office and asks for an extension of
material time of ten (10) days from deadline, or until 6 November
2017 to submit the required Memorandum.
 3) This Motion for Extension is filed in good faith and with honest
intentions and not intended to delay the proceedings of this case or
to defy any court order but for the reasons abovementioned, in the
interest of justice and equity.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court that the Accused be given a material time of ten (10) days
from the original deadline, or until 6 November 2017, to file his
Memorandum, in the interest of justice and equity.

Other reliefs and remedies as are just and equitable under the premises
are likewise prayed for.

Most respectfully submitted.

25 October 2017, Cagayan de Oro City.

GUIBONE & GUIBONE LAW OFFICE

Counsel for Accused
Corner 2nd-3rd Sts., Nazareth, Cagayan de Oro City
By:

ATTY. CANCIO NICANOR M. GUIBONE, JR.

IBP No. 1059515, 1-6-17, Mis. Or.
PTR No. 8006988, 1-6-17, Mis. Or.
Roll No. 47982, TIN 181-521-566
MCLE Compliance No. V-0000814, 29 October 2013
Cagayan de Oro City
0997-7491995 / 0920-9477048

NOTICE
CLERK OF COURT
Municipal Circuit Trial Court of Maigo-Bacolod-Munai
Bacolod, Lanao del Norte

PROVINCIAL PROSECUTOR
Office of the Provincial Prosecutor
Hall of Justice, Iligan City

GREETINGS:

Please submit the foregoing Motion unto the Honorable Court

immediately upon receipt hereof for its kind resolution and approval, sans
appearance.
 ATTY. CANCIO NICANOR M. GUIBONE, JR.

Copy furnished:

PROVINCIAL PROSECUTOR
Office of the Provincial Prosecutor
Hall of Justice, Iligan City