REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

7th Judicial Region
BRANCH XI
Cebu City

PEOPLE OF THE PHILIPPINES, CRIM.CASES NOS. AR-7012,

Plaintiff, AR-7013, AR-7014 and AR-7015

- versus - - For -

LEILANI TAN BAYLON, VIOLATION OF SEC. 4, RA 10175

Accused. IN RELATION TO ART. 355, RPC
x --------------------/

URGENT MOTION FOR POSTPONEMENT

WITH MANIFESTATION
1
The undersigned counsel for the accused, in the above-captioned
and docketed criminal cases, and unto this Honorable Court, most
respectfully moves urgently for the deferment of the trial of these
criminal cases, which has been set for hearing on February 3, 2021, at
1:30 p.m. before the sala of this Honorable Court, due to uncontrollable
conditions triggered by real and more contagious variant of the
coronavirus that has raised alarm in our country today—in fact it has
been reported that the new mutated version of this pandemic has
entered Sabah and parts of Tawi-Tawi, which is quite nearer to the
province of Zamboanga del Sur where infections are soaring and the
number of hospitalized COVID-19 patients has surpassed the first peak
seen in the past months. Additionally, the local government of Pagadian
City, Zamboanga del Sur where the undersigned presently resides has
already imposed urgency to stop indifinetely all flights from
Pagadian
URGENT MOTION FOR POSTPONEMENT WITH MANIFESTATION
CRIMINAL CASES NOS. AR-7012, AR-7013, AR-7014 and AR-7015
PEOPLE VS. BAYLON FOR VIOLATION OF SEC. 4, RA 10175, ETC.
X===================================/ PAGE 2

City to Cebu City, and vice versa, as well as to restrict in its maximum
level the travel outside Pagadian City and Zamboanga del Sur of all
senior citizens (like the undersigned who is already more than 68 years
old and have been suffering from type II diabetes with hypertension).
II
And undersigned hereby most respectfully MANIFESTS that he has
not, as yet, notified in writing, if any, regarding the Demurrer To
Evidence he filed in connection to all these criminal cases, whether
same is denied. This motion is not intended to delay the proceedings
of this Honorable Court, nor resorted to for the purpose of thwarting
the prompt disposition of these criminal cases.

WHEREFORE, in the interest of a more broader ground of justice

and for humantitarian reasons, the undersigned hereby prays that this
URGENT MOTION FOR POSTPONEMENT WITH MANIFESTATION be
given due course, and that the continuation of the hearing of the above
entitled and docketed criminal cases be preferably moved to the third
week of May, 2021, at 1:30 P.M.

January 13, 2021, Pagadian City, for Cebu City, Philippines.

ATTY. LUCIO ORIO TAN, JR.

Collaborating Counsel for the Accused
Phase 1, Purok Mahigugma-on
Vettalea Highland Homes Subdivision
Bulatok, Pagadian City, Zamboanga del Sur
IBP Lifetime Member No. 01571
PTR No. 1703891 / 03-11-2019 / Cebu City
Roll of Attorneys No. 446556
MCLE Compliance No. VI-0000019 dated 04/20/16
Email Address: luciooriotan65@yahoo.com
Contact No. 0945-4276776
URGENT MOTION FOR POSTPONEMENT WITH MANIFESTATION
CRIMINAL CASES NOS. AR-7012, AR-7013, AR-7014 and AR-7015
PEOPLE VS. BAYLON FOR VIOLATION OF SEC. 4, RA 10175, ETC.
X===================================/ PAGE 3

REQUEST FOR SUBMISSION

THE BRANCH CLERK OF COURT

RTC, 7th Judicial Region
BRANCH XI
Cebu City

Sir/Ma’am:

You are respectfully requested to kindly submit the foregoing

URGENT MOTION FOR POSTPONEMENT WITH MANIFESTATION to the
Presiding Judge, HON. RAMON B. DAOMILAS JR. of the Regional Trial
Court, Branch XI, Cebu City, for his kind consideration sans further
argument.
Thank you.
ATTY. LUCIO ORIO TAN, JR.

Copy Furnished:
1. Ass’t. Prosecutor, Hon. ROSEMARIE PABATAO
Office of the Provincial Prosecutor
Hall of Justice, Cebu City
Thru LBC with Tracking Numbers ___________
Dated ________________________________

2. Atty. RICHER P. DEVERATURDA

Counsel for the Private Complainant
MALILONG & CABATINGAN LAW OFFICES
2/F Don Carlos A. Gothong Port Centre
Quezon Blvd., Pier 4, North Reclamation Area
Cebu City, Thru LBC with Tracking Numbers ___________
_________________ Dated _______________________
URGENT MOTION FOR POSTPONEMENT WITH MANIFESTATION
CRIMINAL CASES NOS. AR-7012, AR-7013, AR-7014 and AR-7015
PEOPLE VS. BAYLON FOR VIOLATION OF SEC. 4, RA 10175, ETC.
X===================================/ PAGE 4

[EXPLANATION]

Original copies of the foregoing URGENT MOTION FOR

POSTPONEMENT WITH MANIFESTATION were filed with the above-
named Court and duplicate copies thereof were served upon private
complainant’s public prosecutor and private counsel, respectively, thru
LBC, which is an authorized courier service for the reason that personal
service is not practicable due to great distance between the address of
the undersigned where he is presently holding office at Pagadian City,
Zamboanga del Sur (Western Mindanao Region), and the location of the
aforementioned Court, as well as the office of the handling Public
Prosecutor and Private Counsel, respectively, which are all situated in
Cebu City (Western Visayas Region).

ATTY. LUCIO ORIO TAN, JR.