Republic of the Philippines

DEPARTMENT OF AGRARIAN REFORM

PROVINCIAL OFFICE-CAMARINES SUR
Doña Dolores Bldg., Roxas Avenue
Diversion Road, Triangulo
Naga City, Camarines Sur

IN RE: PETITION FOR

CANCELLATION OF CLOA NO.
00124402, OCT NO. 3653, IN THE NAME
OF LEONOR B. STA. ANA, ET.AL DUE
TO ERRONEOUS IDENTIFICATION APO NO. __________
OF FARMER-BENEFICIARY.

SULPICIO L. PAVIO (FABEYO), MA.

GRACE E. CELZO, RONA F. FELICITAS
& NEMIA F. IBAY,
Petitioners,

-versus-

LEONOR B. STA. ANA, DENNIS

JUNNEL STA. ANA, SHIELA DARILAY
AND MA. PERLA CELESTE,
Private Respondents.

DAR PROVINCIAL OFFICE OF

CAMARINES SUR II,
Represented by Provincial Agrarian
Reform Officer II
Public Respondent.
and

ATTY. VICTORIANO D. CAUBANG II,

in his capacity as the REGISTER OF
DEEDS OF CAMARINES SUR,

Nominal Public Party

Respondent

x--------------------------------------x
 MOTION FOR EXTENSION OF TIME TO FILE POSITION
PAPER AND DRAFT DECISION
Private Respondents, represented by Dennis Junnel B. Sta. Ana, by
counsel, to this Honorable Office, most respectfully state that:

1. The undersigned counsel, received a copy of the Order of this

Honorable Office dated March 12, 2019 on May 6, 2019 directing the
Respondents, to submit a Position Paper together with the draft decision
within ten (10) days from receipt or until May 16, 2019;

2. However, due to the volume and pressure of work, coupled with

other equally important and urgent professional commitments, the
undersigned counsel cannot submit the required documents within the
period required and will need an additional ten (10) days from May 16,
2019 or until May 26, 2019 within which to submit the same;
3. This motion is being filed due to the reason above-stated and not for
the purpose of delaying the instant case.

PRAYER

WHEREFORE, Private Respondents, through counsel, respectfully

pray that they be granted an additional ten (10) days from May 16, 2019 or
until May 26, 2019 within which to submit the required Position Paper and
draft decision.

Other reliefs deemed just, proper and equitable in the premises are
likewise most respectfully prayed for.

Naga City for Philippines, May 16, 2018.

By:

LEO ARCHIVAL I. IMPERIAL

Counsel for the Plaintiffs
Unit 2D, Prifel Bldg. J. Miranda Ave., Naga City
ROLL NO. 60619-March 23, 2012
IBP No. 0294- CY-2019
PTR No. 0418426- January 7, 2019
MCLE Compliance No. VI-0003390, October 12, 2017
Tel No: 472-82-61/C.P. No: 09175126032

Copy Furnished: By Registered Mail

ATTY. RODEL ABOGADO

Counsel for Petitioners
Public Attorney’s Office
Naga City, Camarines Sur

Explanation: On account of the distance, time and personnel constraints in effecting

personal service, counsel for the Private Respondents is constrained to serve a copy of
the foregoing motion to the counsel of the Petitioners at his address above through
registered mail as evidenced by hereto attached Registry Receipt No:__________.

ATTY. LEO ARCHIVAL I. IMPERIAL

REPUBLIC OF THE PHILIPPINES)
Province of ____________________) S.S.
City/Municipality of _____________)
x-----------------------x

AFFIDAVIT OF SERVICE

I, ATTY. LEO ARCHIVAL I. IMPERIAL, of legal age, married, and with office
address at Unit 2-D, Prifel Bldg., J. Miranda Ave., Naga City, Camarines Sur, after
having been duly sworn in accordance with law, hereby depose and say:
 1. That in my aforementioned capacity, I had served a copy of the “MOTION FOR
EXTENSION OF TIME TO FILE COMMENT ON THE PETITION FOR REVIEW” in
the case entitled "JESUS PESIMO, JR., ET. AL. VS. HEIRS OF SALVACION
VALER, ETC..," docketed as CA G.R. SP. NO. 156924 by registered mail to the
office of Atty. Jamara Leigh C. Fernandez and Atty. Regine Joy l. Magabo, with
office address at DOJ Public Attorney’s Office (Special and Appealed Cases
Service) 5/F DOJ Agencies Bldg. NIA Road cor. East Ave., Diliman, 1104, Quezon
City;

2. That I also served a copy of said pleading with the Court of Appeals with address
at Ma. Orosa St., Manila by registered mail; and

3. That service was made by registered mail on account of the distance, time and
personnel constraints in effecting personal service.

IN WITNESS WHEREOF, I have hereunto set my hand this _____________ at

_____________, Philippines.

ATTY. LEO ARCHIVAL I. IMPERIAL

Affiant
UMID CRN-0111-0898561-5

SUBSCRIBED AND SWORN to before me, this _____________, by the Affiant

whom I have identified through his competent evidence of identity as indicated above
and.

NOTARY PUBLIC

Doc. No. ______;

Page No. ______;
Book No.______;
Series of 20____.