Republic of the Philippines

REGIONAL TRIAL COURT

7th Judicial Region
Branch ___
Tagbilaran City

ROBERTO R. ORIG and the HEIRS

OF GERTRUDES L. ORIG
represented by RAUL LLENA, Civil Case No. 8782
Plaintiffs,
For:

-versus- ANNULMENT OF
DONATION,
CANCELLATION OF
TITLE, RECOVERY OF
THE HEIRS OF THE LATE POSSESSION WITH
NICODEMUS ORIG represented DAMAGES
by his wife, ANICETA L. ORIG,
DEPARTMENT OF ENVIRONMENT
AND NATURAL RESOURCES
(DENR) BOHOL, PROVINCIAL
REGISTER OF DEEDS,
MUNICIPALITY OF BALILIHAN,
BOHOL and LAND BANK OF THE
PHILIPPINES, TAGBILARAN CITY
BRANCH, BOHOL
Defendants.
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MOTION FOR EXTENSION OF TIME TO FILE
ANSWER WITH ENTRY OF APPEARANCE

The PROVINCIAL LEGAL OFFICE (PLO), unto this Honorable

Court, most respectfully enters its appearance as counsel for
defendant Municipality of Balilihan, Bohol and further states, THAT:

1. The said defendant received the Summons of the above-

entitled case on _________________ and has fifteen (15) days from
receipt thereof within which to file its Answer or until ___________,
2016.

2. Just today, the defendant engaged the legal services of the

PLO and it would be presumptuous on the part of the handling lawyers
to undertake that they can prepare a responsive pleading within the
remaining time allowed considering that they have other equally
important legal commitments to attend to. Hence, this motion.

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 3. This motion is filed in good faith and without any intention
to delay the proceedings of the case but solely on the reason stated
herein
PRAYER

PREMISES CONSIDERED, it is most respectfully prayed unto

this Honorable Court that defendant Municipality of Balilihan, Bohol be
given an extension of ten (10) days from today, November 23, 2016,
to file its Answer through the undersigned counsels. Other remedies
and reliefs that are just and equitable under the premises are likewise
prayed for.

November 23, 2016, Tagbilaran City, Bohol, Philippines.

PROVINCIAL LEGAL OFFICE

Counsel for defendant Municipality of Balilihan, Bohol
2/F Old DepEd Building, CPG Sports Complex
CPG Avenue, Tagbilaran City, Bohol

By:

MENEDIO THADEUS P. BERNIDO

Legal Officer
IBP Lifetime No. 013402, Bohol Chapter
PTR No. 0279157, Dec. 18, 2015 (for CY 2016), Tagbilaran City
MCLE Compliance No. IV-0001621, issued on 02.22.11
MCLE Compliance No. V-0000498, issued on 10.09.13
Roll No. 51975, 05.10.06
TIN 924.143.517

GWENDOLYN P. MEDEQUISO
IBP No. 1042521, Bohol Chapter
PTR No. 0089030 (for CY 2016), Maribojoc, Bohol
Roll No. 65050
TIN 491-060-112-000

With my conformity:

MAYOR PUREZA V. CHATTO

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THE CLERK OF COURT
Regional Trial Court of Bohol, Br. ____
Tagbilaran City

Greetings! Please submit the above-motion to the Honorable

Court immediately upon receipt thereof for its consideration and
resolution without further arguments and presence of the undersigned
counsel. Thank you.

MENEDIO THADEUS P. BERNIDO

ATTY. DANILO BANTUGAN

Counsel for the Plaintiff
2/F Manigue Building
M.H. Del Pilar St.
Tagbilaran

Greetings! Please be notified that the undersigned counsel is

submitting to the Honorable Court the above-motion immediately upon
receipt thereof for its consideration and resolution without further
arguments and his presence. Thank you.

MENEDIO THADEUS P. BERNIDO