Republic of the Philippines

PROVINCE OF PANGASINAN
REGIONAL TRIAL COURT
First Judicial Region
Urdaneta City
Branch 47

CEASAR CAUTO ET.AL

Plaintiffs,

CIVIL CASE NO. U-11344

-versus-

HEIRS OF ROSALINA
ROSQUETA, Namely: LILI
ROSQUETA-ROSALES,
NORMA ROSQUETA-
MONTEMAYOR and
EMMA M. ROSQUETA.
Defendants,
x--------------------------------------------------x

MOTION TO EXTEND MEDIATION

Defendants Heirs Of Rosalina Rosqueta, Namely: Lili Rosqueta-

Rosales, Norma Rosqueta-Montemayor And Emma M. Rosqueta.
(hereinafter referred to as “Defendants”) by counsel, unto this
Honorable Court, respectfully state:

1. On 04 March 2021, Defendants received from this

Honorable Court, a copy of the Order referring the case to the
Philippine Mediation Center (PMC) in Urdaneta City scheduled on
11 March 2021.

2. On 11 March 2021, the undersigned counsel attended the

Mediation at the Philippine Mediation Center in Urdaneta City.
During the mediation, it was respectfully requested by the
undersigned counsel to move the mediation to a later date because
the Authorized Representative of the Defendants, Ms. Emma M.
Rosqueta, was hospitalized for surgery due to her fracture. The
Honorable Mediator granted the request and reschedule the
mediation on 12 April 2021.

3. According to A.M No. 05-10-5-SC-PHILJA, the period of

mediation shall not exceed thirty (30) days. At the end of the thirty-
day period allowed by the trial court, if no settlement has been
reached, the cases must be returned to the trial court for further
proceedings, unless the parties agree to further continue the
mediation, in which case, a last extension of thirty (30) days may be
granted by the trial court.

4. Ms. Emma Rosqueta is willing to attend the Mediation in

the Philippine Mediation Center in Urdaneta. However, she is still
recovering from her surgery, and she still cannot afford to attend the
said Mediation in Urdaneta City. In addition to that, as COVID-19
continuously surges in the Philippines, she is hesitant to go out of her
home because she is considered a high-risk individual who may be
severely affected by the COVID-19 virus due to her old age and
health condition. The undersigned counsel is constrained to ask for
an additional thirty (30) days from 12 April 2021 or until 12 May 2021
to extend the conduct of the said Mediation.

5. This Motion is not intended to delay the proceedings but

is solely necessitated by the just and equitable reasons stated above.

PRAYER

Wherefore, Defendants Heirs Of Rosalina Rosqueta, Namely:

Lili Rosqueta-Rosales, Norma Rosqueta-Montemayor And Emma M.
Rosquet), respectfully prays that this Honorable Office grant thirty
(30) days from 12 April 2021 or until 12 May 2021 to extend the said
Mediation.
.

Other reliefs just and equitable are likewise prayed for.

Taguig City for Urdaneta City, April 2021.

BATUHAN BLANDO CONCEPCION & TRILLANA LAW FIRM

Counsel for Defendat
15 Floor, Picadilly Star Building,
th

4th Ave., cor 27th Street

Bonifacio Global City, Taguig City

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 Telephone Number:  846-8004
Email Address:  bbctlaw@bbclawoffice.net

By:

JOSELITO JOHN G. BLANDO

PTR No. A-5074940; 4 January 2021; Taguig City
IBP No. 1031998; Lifetime Member No. 014482 – Feb. 19, 2016;
Makati City Chapter
Roll of Attorneys No. 38555
MCLE Compliance No. VI-0007352 - 21 March 2018

MIKEE ANGELU S. PORTES

PTR No. A-5095598; 19 January 2021; Taguig City
IBP No. 153796; 19 January 2021; Quezon Chapter
Roll of Attorneys No. 74929
MCLE Compliance No. N/A (Admitted to the Bar July 2020)

NOTICE OF HEARING

Greetings:

Please be informed that the undersigned counsel is submitting

the foregoing Motion for the consideration and approval of this
Honorable Office.

JOSELITO G. BLANDO

EXPLANATION

The undersigned caused the filing and service of the motion to

extend the meditation to the person/s stated above through
registered mail and private courier due to distance and lack of
available messengers to effect personal service.

JOSELITO G. BLANDO

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Copy Furnished:

Atty. Edlice Grace U. Rojo

Counsel for Plaintiffs
47 Zone V, Mc Arthur Highway,
Villasis Pangasinan

Atty. Jenor P. Sannad

Room 2, 2F, Vinuya Bldg, Tiong St.
Manaoag Pangasinan

Philippine Mediation Center

Urdaneta City, Pangasinan