Republic of the Philippines

PHILIPPINE HEALTH INSURANCE CORPORATION

Citystate Centre Building, 709 Shaw Boulevard, Pasig City
Call Center (02)4 441-7742 l Trunkline : (02) 441-74444
www.philhealth.gov.ph

PHILIPPINE HEALTH PROSEC REF No.

INSURANCE CORPORATION 10072020-CA-XI-3628
Complainant,
For: Alleged violation of
- versus - the Revised Implementing
Rules and Regulations
COMPOSTELA VALLEY (RIRR) of RA 7875, as
PROVINCIAL HOSPITAL- amended.
MONTEVISTA, FERDINAND
ANTHONY C. SOBERANO,
M.D., and FLORENCIA S.
ANDRES, M.D., FPSMS, MHA,
Respondents.
x-------------------------------x

COMES NOW, Respondents, Compostela Valley Provincial

Hospital-Montevista (now Davao de Oro Provincial Hospital-
Montevista), duly represented by Gov. Jayvee Tyron L. Uy,
Ferdinand Anthony C. Soberano, M.D., in his capacity as Chief of
Hospital/Medical Director of the said Facility and the authorized
hospital representative/signatory to the claim, and Florencia S.
Andres, M.D., FPSMS, MHA, through the undersigned counsel,
unto this Honorable Office, by way of Answer, hereby states,
THAT:

1. On March 4, 2021, Respondents received a directive dated

January 19, 2021 from this Honorable Office requiring the
latter to submit their respective verified answer on the above-
captioned case within five (5) days upon receipt of the said
order or until March 9, 2021;

2. In view of the fact that the circumstance of the case transpired

in the year 2015 or five years ago, respondents are still in the
process of consolidating their respective supporting documents
and preparing the affidavits of their witnesses in evidence for
their defense, the allocated time given is not ample enough for
them to make their comprehensive written answer;
3. However, considering the closeness of the deadline and the
undersigned counsel has yet to review thoroughly the
Complaint as well as the documents in relation to the
complaint;

4. As such, the undersigned counsel is constrained to request for

an additional period of 15 days from March 10, 2021 or
until March 25, 2021 within which to submit Respondents’
respective verified answer together with the supporting
evidence;

5. This Motion is done in good faith and not intended for delay but
solely due to the foregoing reasons.

II. PRAYER

WHEREFORE, in view of the foregoing, the undersigned

respectfully prays that he be granted an additional fifteen (15)
days from March 10, 2021 or until March 25, 2021 within
which to submit a verified answer.

9 March 2021. Nabunturan, Davao de Oro.

ATTY. NIEL JOHN A. VILLARICO

IBP Lifetime no. 109252
PTR OR No. 0264398-01/04/2021. Davao de Oro
TIN 939-740-159-000
MCLE Compliance No. IV-0013948 valid until 4/14/2022
 Republic of the Philippines
PHILIPPINE HEALTH INSURANCE CORPORATION
Citystate Centre Building, 709 Shaw Boulevard, Pasig City
Call Center (02)4 441-7742 l Trunkline : (02) 441-74444
www.philhealth.gov.ph

PHILIPPINE HEALTH PROSEC REF No.

INSURANCE CORPORATION 10072020-CA-XI-3630
Complainant,
For: Alleged violation of
- versus - the Revised Implementing
Rules and Regulations
COMPOSTELA VALLEY (RIRR) of RA 7875, as
PROVINCIAL HOSPITAL- amended.
MONTEVISTA, FERDINAND
ANTHONY C. SOBERANO,
M.D., and VENN RAINER V.
CUARTE, M.D.,
Respondents.
x-------------------------------x

COMES NOW, Respondents, Compostela Valley Provincial

Hospital-Montevista (now Davao de Oro Provincial Hospital-
Montevista), duly represented by Gov. Jayvee Tyron L. Uy,
Ferdinand Anthony C. Soberano, M.D., in his capacity as Chief of
Hospital/Medical Director of the said Facility and the authorized
hospital representative/signatory to the claim, and Venn Rainer
V. Cuarte, M.D., through the undersigned counsel, unto this
Honorable Office, by way of Answer, hereby states, THAT:

1. On March 4, 2021, Respondents received a directive dated

January 19, 2021 from this Honorable Office requiring the
latter to submit their respective verified answer on the
above-captioned case within five (5) days upon receipt of
the said order or until March 9, 2021;

2. In view of the fact that the circumstance of the case

transpired in the year 2015 or five years ago, respondents
are still in the process of consolidating their respective
supporting documents and preparing the affidavits of their
witnesses in evidence for their defense, the allocated time
given is not ample enough for them to make their
comprehensive written answer;
 3. However, considering the closeness of the deadline and the
undersigned counsel has yet to review thoroughly the
Complaint as well as the documents in relation to the
complaint;

4. As such, the undersigned counsel is constrained to request

for an additional period of 15 days from March 10, 2021
or until March 25, 2021 within which to submit
Respondents’ respective verified answer together with the
supporting evidence;

5. This Motion is done in good faith and not intended for delay
but solely due to the foregoing reasons.

II. PRAYER

WHEREFORE, in view of the foregoing, the undersigned

respectfully prays that he be granted an additional fifteen (15)
days from March 10, 2021 or until March 25, 2021 within
which to submit a verified answer.

9 March 2021. Nabunturan, Davao de Oro.

ATTY. NIEL JOHN A. VILLARICO

IBP Lifetime no. 109252
PTR OR No. 0264398-01/04/2021. Davao de Oro
TIN 939-740-159-000
MCLE Compliance No. IV-0013948 valid until 4/14/2022
 Republic of the Philippines
PHILIPPINE HEALTH INSURANCE CORPORATION
Citystate Centre Building, 709 Shaw Boulevard, Pasig City
Call Center (02)4 441-7742 l Trunkline : (02) 441-74444
www.philhealth.gov.ph

PHILIPPINE HEALTH PROSEC REF No.

INSURANCE CORPORATION 10072020-CA-XI-3631
Complainant,
For: Alleged violation of
- versus - the Revised Implementing
Rules and Regulations
COMPOSTELA VALLEY (RIRR) of RA 7875, as
PROVINCIAL HOSPITAL- amended.
MONTEVISTA, FERDINAND
ANTHONY C. SOBERANO,
M.D., and VENN RAINER V.
CUARTE, M.D.,
Respondents.
x-------------------------------x

COMES NOW, Respondents, Compostela Valley Provincial

Hospital-Montevista (now Davao de Oro Provincial Hospital-
Montevista), duly represented by Gov. Jayvee Tyron L. Uy,
Ferdinand Anthony C. Soberano, M.D., in his capacity as Chief of
Hospital/Medical Director of the said Facility and the authorized
hospital representative/signatory to the claim, and Venn Rainer
V. Cuarte, M.D., through the undersigned counsel, unto this
Honorable Office, by way of Answer, hereby states, THAT:

1. On March 4, 2021, Respondents received a directive dated

January 19, 2021 from this Honorable Office requiring the
latter to submit their respective verified answer on the
above-captioned case within five (5) days upon receipt of
the said order or until March 9, 2021;

2. In view of the fact that the circumstance of the case

transpired in the year 2015 or five years ago, respondents
are still in the process of consolidating their respective
supporting documents and preparing the affidavits of their
witnesses in evidence for their defense, the allocated time
given is not ample enough for them to make their
comprehensive written answer;
 3. However, considering the closeness of the deadline and the
undersigned counsel has yet to review thoroughly the
Complaint as well as the documents in relation to the
complaint;

4. As such, the undersigned counsel is constrained to request

for an additional period of 15 days from March 10, 2021
or until March 25, 2021 within which to submit
Respondents’ respective verified answer together with the
supporting evidence;

5. This Motion is done in good faith and not intended for delay
but solely due to the foregoing reasons.

II. PRAYER

WHEREFORE, in view of the foregoing, the undersigned

respectfully prays that he be granted an additional fifteen (15)
days from March 10, 2021 or until March 25, 2021 within
which to submit a verified answer.

9 March 2021. Nabunturan, Davao de Oro.

ATTY. NIEL JOHN A. VILLARICO

IBP Lifetime no. 109252
PTR OR No. 0264398-01/04/2021. Davao de Oro
TIN 939-740-159-000
MCLE Compliance No. IV-0013948 valid until 4/14/2022
 Republic of the Philippines
PHILIPPINE HEALTH INSURANCE CORPORATION
Citystate Centre Building, 709 Shaw Boulevard, Pasig City
Call Center (02)4 441-7742 l Trunkline : (02) 441-74444
www.philhealth.gov.ph

PHILIPPINE HEALTH PROSEC REF No.

INSURANCE CORPORATION 10072020-CA-XI-3636
Complainant,
For: Alleged violation of
- versus - the Revised Implementing
Rules and Regulations
COMPOSTELA VALLEY (RIRR) of RA 7875, as
PROVINCIAL HOSPITAL- amended.
MONTEVISTA, FERDINAND
ANTHONY C. SOBERANO,
M.D., and RAMCIS S.
PELEGRINO, M.D.,
Respondents.
x-------------------------------x

COMES NOW, Respondents, Compostela Valley Provincial

Hospital-Montevista (now Davao de Oro Provincial Hospital-
Montevista), duly represented by Gov. Jayvee Tyron L. Uy,
Ferdinand Anthony C. Soberano, M.D., in his capacity as Chief of
Hospital/Medical Director of the said Facility and the authorized
hospital representative/signatory to the claim, and Ramcis S.
Pelegrino, M.D., through the undersigned counsel, unto this
Honorable Office, by way of Answer, hereby states, THAT:

1. On March 4, 2021, Respondents received a directive dated

January 19, 2021 from this Honorable Office requiring the
latter to submit their respective verified answer on the
above-captioned case within five (5) days upon receipt of
the said order or until March 9, 2021;

2. In view of the fact that the circumstance of the case

transpired in the year 2015 or five years ago, respondents
are still in the process of consolidating their respective
supporting documents and preparing the affidavits of their
witnesses in evidence for their defense, the allocated time
given is not ample enough for them to make their
comprehensive written answer;
 3. However, considering the closeness of the deadline and the
undersigned counsel has yet to review thoroughly the
Complaint as well as the documents in relation to the
complaint;

4. As such, the undersigned counsel is constrained to request

for an additional period of 15 days from March 10, 2021
or until March 25, 2021 within which to submit
Respondents’ respective verified answer together with the
supporting evidence;

5. This Motion is done in good faith and not intended for delay
but solely due to the foregoing reasons.

II. PRAYER

WHEREFORE, in view of the foregoing, the undersigned

respectfully prays that he be granted an additional fifteen (15)
days from March 10, 2021 or until March 25, 2021 within
which to submit a verified answer.

9 March 2021. Nabunturan, Davao de Oro.

ATTY. NIEL JOHN A. VILLARICO

IBP Lifetime no. 109252
PTR OR No. 0264398-01/04/2021. Davao de Oro
TIN 939-740-159-000
MCLE Compliance No. IV-0013948 valid until 4/14/2022
 Republic of the Philippines
PHILIPPINE HEALTH INSURANCE CORPORATION
Citystate Centre Building, 709 Shaw Boulevard, Pasig City
Call Center (02)4 441-7742 l Trunkline : (02) 441-74444
www.philhealth.gov.ph

PHILIPPINE HEALTH PROSEC REF No.

INSURANCE CORPORATION 10072020-CA-XI-3637
Complainant,
For: Alleged violation of
- versus - the Revised Implementing
Rules and Regulations
COMPOSTELA VALLEY (RIRR) of RA 7875, as
PROVINCIAL HOSPITAL- amended.
MONTEVISTA, FERDINAND
ANTHONY C. SOBERANO,
M.D., and RAMCIS S.
PELEGRINO, M.D.,
Respondents.
x-------------------------------x

COMES NOW, Respondents, Compostela Valley Provincial

Hospital-Montevista (now Davao de Oro Provincial Hospital-
Montevista), duly represented by Gov. Jayvee Tyron L. Uy,
Ferdinand Anthony C. Soberano, M.D., in his capacity as Chief of
Hospital/Medical Director of the said Facility and the authorized
hospital representative/signatory to the claim, and Ramcis S.
Pelegrino, M.D., through the undersigned counsel, unto this
Honorable Office, by way of Answer, hereby states, THAT:

1. On March 4, 2021, Respondents received a directive dated

January 19, 2021 from this Honorable Office requiring the
latter to submit their respective verified answer on the
above-captioned case within five (5) days upon receipt of
the said order or until March 9, 2021;

2. In view of the fact that the circumstance of the case

transpired in the year 2015 or five years ago, respondents
are still in the process of consolidating their respective
supporting documents and preparing the affidavits of their
witnesses in evidence for their defense, the allocated time
given is not ample enough for them to make their
comprehensive written answer;
 3. However, considering the closeness of the deadline and the
undersigned counsel has yet to review thoroughly the
Complaint as well as the documents in relation to the
complaint;

4. As such, the undersigned counsel is constrained to request

for an additional period of 15 days from March 10, 2021
or until March 25, 2021 within which to submit
Respondents’ respective verified answer together with the
supporting evidence;

5. This Motion is done in good faith and not intended for delay
but solely due to the foregoing reasons.

II. PRAYER

WHEREFORE, in view of the foregoing, the undersigned

respectfully prays that he be granted an additional fifteen (15)
days from March 10, 2021 or until March 25, 2021 within
which to submit a verified answer.

9 March 2021. Nabunturan, Davao de Oro.

ATTY. NIEL JOHN A. VILLARICO

IBP Lifetime no. 109252
PTR OR No. 0264398-01/04/2021. Davao de Oro
TIN 939-740-159-000
MCLE Compliance No. IV-0013948 valid until 4/14/2022
 Republic of the Philippines
PHILIPPINE HEALTH INSURANCE CORPORATION
Citystate Centre Building, 709 Shaw Boulevard, Pasig City
Call Center (02)4 441-7742 l Trunkline : (02) 441-74444
www.philhealth.gov.ph

PHILIPPINE HEALTH PROSEC REF No.

INSURANCE CORPORATION 10072020-CA-XI-3626
Complainant,
For: Alleged violation of
- versus - the Revised Implementing
Rules and Regulations
COMPOSTELA VALLEY (RIRR) of RA 7875, as
PROVINCIAL HOSPITAL- amended.
MONTEVISTA, FERDINAND
ANTHONY C. SOBERANO,
M.D., and FLORENCIA S.
ANDRES, M.D., FPSMS, MHA,
Respondents.
x-------------------------------x

COMES NOW, Respondents, Compostela Valley Provincial

Hospital-Montevista (now Davao de Oro Provincial Hospital-
Montevista), duly represented by Gov. Jayvee Tyron L. Uy,
Ferdinand Anthony C. Soberano, M.D., in his capacity as Chief of
Hospital/Medical Director of the said Facility and the authorized
hospital representative/signatory to the claim, and Florencia S.
Andres, M.D., FPSMS, MHA, through the undersigned counsel,
unto this Honorable Office, by way of Answer, hereby states,
THAT:

1. On March 4, 2021, Respondents received a directive dated

January 19, 2021 from this Honorable Office requiring the
latter to submit their respective verified answer on the
above-captioned case within five (5) days upon receipt of
the said order or until March 9, 2021;

2. In view of the fact that the circumstance of the case

transpired in the year 2015 or five years ago, respondents
are still in the process of consolidating their respective
supporting documents and preparing the affidavits of their
witnesses in evidence for their defense, the allocated time
given is not ample enough for them to make their
comprehensive written answer;
 3. However, considering the closeness of the deadline and the
undersigned counsel has yet to review thoroughly the
Complaint as well as the documents in relation to the
complaint;

4. As such, the undersigned counsel is constrained to request

for an additional period of 15 days from March 10, 2021
or until March 25, 2021 within which to submit
Respondents’ respective verified answer together with the
supporting evidence;

5. This Motion is done in good faith and not intended for delay
but solely due to the foregoing reasons.

II. PRAYER

WHEREFORE, in view of the foregoing, the undersigned

respectfully prays that he be granted an additional fifteen (15)
days from March 10, 2021 or until March 25, 2021 within
which to submit a verified answer.

9 March 2021. Nabunturan, Davao de Oro.

ATTY. NIEL JOHN A. VILLARICO

IBP Lifetime no. 109252
PTR OR No. 0264398-01/04/2021. Davao de Oro
TIN 939-740-159-000
MCLE Compliance No. IV-0013948 valid until 4/14/2022
 Republic of the Philippines
PHILIPPINE HEALTH INSURANCE CORPORATION
Citystate Centre Building, 709 Shaw Boulevard, Pasig City
Call Center (02)4 441-7742 l Trunkline : (02) 441-74444
www.philhealth.gov.ph

PHILIPPINE HEALTH PROSEC REF No.

INSURANCE CORPORATION 10072020-CA-XI-3627
Complainant,
For: Alleged violation of
- versus - the Revised Implementing
Rules and Regulations
COMPOSTELA VALLEY (RIRR) of RA 7875, as
PROVINCIAL HOSPITAL- amended.
MONTEVISTA, FERDINAND
ANTHONY C. SOBERANO,
M.D., and FLORENCIA S.
ANDRES, M.D., FPSMS, MHA,
Respondents.
x-------------------------------x

COMES NOW, Respondents, Compostela Valley Provincial

Hospital-Montevista (now Davao de Oro Provincial Hospital-
Montevista), duly represented by Gov. Jayvee Tyron L. Uy,
Ferdinand Anthony C. Soberano, M.D., in his capacity as Chief of
Hospital/Medical Director of the said Facility and the authorized
hospital representative/signatory to the claim, and Florencia S.
Andres, M.D., FPSMS, MHA, through the undersigned counsel,
unto this Honorable Office, by way of Answer, hereby states,
THAT:

1. On March 4, 2021, Respondents received a directive dated

January 19, 2021 from this Honorable Office requiring the
latter to submit their respective verified answer on the
above-captioned case within five (5) days upon receipt of
the said order or until March 9, 2021;

2. In view of the fact that the circumstance of the case

transpired in the year 2015 or five years ago, respondents
are still in the process of consolidating their respective
supporting documents and preparing the affidavits of their
witnesses in evidence for their defense, the allocated time
given is not ample enough for them to make their
comprehensive written answer;
 3. However, considering the closeness of the deadline and the
undersigned counsel has yet to review thoroughly the
Complaint as well as the documents in relation to the
complaint;

4. As such, the undersigned counsel is constrained to request

for an additional period of 15 days from March 10, 2021
or until March 25, 2021 within which to submit
Respondents’ respective verified answer together with the
supporting evidence;

5. This Motion is done in good faith and not intended for delay
but solely due to the foregoing reasons.

II. PRAYER

WHEREFORE, in view of the foregoing, the undersigned

respectfully prays that he be granted an additional fifteen (15)
days from March 10, 2021 or until March 25, 2021 within
which to submit a verified answer.

9 March 2021. Nabunturan, Davao de Oro.

ATTY. NIEL JOHN A. VILLARICO

IBP Lifetime no. 109252
PTR OR No. 0264398-01/04/2021. Davao de Oro
TIN 939-740-159-000
MCLE Compliance No. IV-0013948 valid until 4/14/2022
 Republic of the Philippines
PHILIPPINE HEALTH INSURANCE CORPORATION
Citystate Centre Building, 709 Shaw Boulevard, Pasig City
Call Center (02)4 441-7742 l Trunkline : (02) 441-74444
www.philhealth.gov.ph

PHILIPPINE HEALTH PROSEC REF No.

INSURANCE CORPORATION 10072020-CA-XI-3622
Complainant,
For: Alleged violation of
- versus - the Revised Implementing
Rules and Regulations
COMPOSTELA VALLEY (RIRR) of RA 7875, as
PROVINCIAL HOSPITAL- amended.
MONTEVISTA, FERDINAND
ANTHONY C. SOBERANO,
M.D., and FLORENCIA S.
ANDRES, M.D., FPSMS, MHA,
Respondents.
x-------------------------------x

COMES NOW, Respondents, Compostela Valley Provincial

Hospital-Montevista (now Davao de Oro Provincial Hospital-
Montevista), duly represented by Gov. Jayvee Tyron L. Uy,
Ferdinand Anthony C. Soberano, M.D., in his capacity as Chief of
Hospital/Medical Director of the said Facility and the authorized
hospital representative/signatory to the claim, and Florencia S.
Andres, M.D., FPSMS, MHA, through the undersigned counsel,
unto this Honorable Office, by way of Answer, hereby states,
THAT:

1. On March 4, 2021, Respondents received a directive dated

January 19, 2021 from this Honorable Office requiring the
latter to submit their respective verified answer on the
above-captioned case within five (5) days upon receipt of
the said order or until March 9, 2021;

2. In view of the fact that the circumstance of the case

transpired in the year 2015 or five years ago, respondents
are still in the process of consolidating their respective
supporting documents and preparing the affidavits of their
witnesses in evidence for their defense, the allocated time
given is not ample enough for them to make their
comprehensive written answer;
 3. However, considering the closeness of the deadline and the
undersigned counsel has yet to review thoroughly the
Complaint as well as the documents in relation to the
complaint;

4. As such, the undersigned counsel is constrained to request

for an additional period of 15 days from March 10, 2021
or until March 25, 2021 within which to submit
Respondents’ respective verified answer together with the
supporting evidence;

5. This Motion is done in good faith and not intended for delay
but solely due to the foregoing reasons.

II. PRAYER

WHEREFORE, in view of the foregoing, the undersigned

respectfully prays that he be granted an additional fifteen (15)
days from March 10, 2021 or until March 25, 2021 within
which to submit a verified answer.

9 March 2021. Nabunturan, Davao de Oro.

ATTY. NIEL JOHN A. VILLARICO

IBP Lifetime no. 109252
PTR OR No. 0264398-01/04/2021. Davao de Oro
TIN 939-740-159-000
MCLE Compliance No. IV-0013948 valid until 4/14/2022
 Republic of the Philippines
PHILIPPINE HEALTH INSURANCE CORPORATION
Citystate Centre Building, 709 Shaw Boulevard, Pasig City
Call Center (02)4 441-7742 l Trunkline : (02) 441-74444
www.philhealth.gov.ph

PHILIPPINE HEALTH PROSEC REF No.

INSURANCE CORPORATION 10072020-CA-XI-3624
Complainant,
For: Alleged violation of
- versus - the Revised Implementing
Rules and Regulations
COMPOSTELA VALLEY (RIRR) of RA 7875, as
PROVINCIAL HOSPITAL- amended.
MONTEVISTA, FERDINAND
ANTHONY C. SOBERANO,
M.D., and FLORENCIA S.
ANDRES, M.D., FPSMS, MHA,
Respondents.
x-------------------------------x

COMES NOW, Respondents, Compostela Valley Provincial

Hospital-Montevista (now Davao de Oro Provincial Hospital-
Montevista), duly represented by Gov. Jayvee Tyron L. Uy,
Ferdinand Anthony C. Soberano, M.D., in his capacity as Chief of
Hospital/Medical Director of the said Facility and the authorized
hospital representative/signatory to the claim, and Florencia S.
Andres, M.D., FPSMS, MHA, through the undersigned counsel,
unto this Honorable Office, by way of Answer, hereby states,
THAT:

1. On March 4, 2021, Respondents received a directive dated

January 19, 2021 from this Honorable Office requiring the
latter to submit their respective verified answer on the
above-captioned case within five (5) days upon receipt of
the said order or until March 9, 2021;

2. In view of the fact that the circumstance of the case

transpired in the year 2015 or five years ago, respondents
are still in the process of consolidating their respective
supporting documents and preparing the affidavits of their
witnesses in evidence for their defense, the allocated time
given is not ample enough for them to make their
comprehensive written answer;
 3. However, considering the closeness of the deadline and the
undersigned counsel has yet to review thoroughly the
Complaint as well as the documents in relation to the
complaint;

4. As such, the undersigned counsel is constrained to request

for an additional period of 15 days from March 10, 2021
or until March 25, 2021 within which to submit
Respondents’ respective verified answer together with the
supporting evidence;

5. This Motion is done in good faith and not intended for delay
but solely due to the foregoing reasons.

II. PRAYER

WHEREFORE, in view of the foregoing, the undersigned

respectfully prays that he be granted an additional fifteen (15)
days from March 10, 2021 or until March 25, 2021 within
which to submit a verified answer.

9 March 2021. Nabunturan, Davao de Oro.

ATTY. NIEL JOHN A. VILLARICO

IBP Lifetime no. 109252
PTR OR No. 0264398-01/04/2021. Davao de Oro
TIN 939-740-159-000
MCLE Compliance No. IV-0013948 valid until 4/14/2022
 Republic of the Philippines
PHILIPPINE HEALTH INSURANCE CORPORATION
Citystate Centre Building, 709 Shaw Boulevard, Pasig City
Call Center (02)4 441-7742 l Trunkline : (02) 441-74444
www.philhealth.gov.ph

PHILIPPINE HEALTH PROSEC REF No.

INSURANCE CORPORATION 10072020-CA-XI-3621
Complainant,
For: Alleged violation of
- versus - the Revised Implementing
Rules and Regulations
COMPOSTELA VALLEY (RIRR) of RA 7875, as
PROVINCIAL HOSPITAL- amended.
MONTEVISTA, FERDINAND
ANTHONY C. SOBERANO,
M.D., and FLORENCIA S.
ANDRES, M.D., FPSMS, MHA,
Respondents.
x-------------------------------x

COMES NOW, Respondents, Compostela Valley Provincial

Hospital-Montevista (now Davao de Oro Provincial Hospital-
Montevista), duly represented by Gov. Jayvee Tyron L. Uy,
Ferdinand Anthony C. Soberano, M.D., in his capacity as Chief of
Hospital/Medical Director of the said Facility and the authorized
hospital representative/signatory to the claim, and Florencia S.
Andres, M.D., FPSMS, MHA, through the undersigned counsel,
unto this Honorable Office, by way of Answer, hereby states,
THAT:

1. On March 4, 2021, Respondents received a directive dated

January 19, 2021 from this Honorable Office requiring the
latter to submit their respective verified answer on the
above-captioned case within five (5) days upon receipt of
the said order or until March 9, 2021;

2. In view of the fact that the circumstance of the case

transpired in the year 2015 or five years ago, respondents
are still in the process of consolidating their respective
supporting documents and preparing the affidavits of their
witnesses in evidence for their defense, the allocated time
given is not ample enough for them to make their
comprehensive written answer;
 3. However, considering the closeness of the deadline and the
undersigned counsel has yet to review thoroughly the
Complaint as well as the documents in relation to the
complaint;

4. As such, the undersigned counsel is constrained to request

for an additional period of 15 days from March 10, 2021
or until March 25, 2021 within which to submit
Respondents’ respective verified answer together with the
supporting evidence;

5. This Motion is done in good faith and not intended for delay
but solely due to the foregoing reasons.

II. PRAYER

WHEREFORE, in view of the foregoing, the undersigned

respectfully prays that he be granted an additional fifteen (15)
days from March 10, 2021 or until March 25, 2021 within
which to submit a verified answer.

9 March 2021. Nabunturan, Davao de Oro.

ATTY. NIEL JOHN A. VILLARICO

IBP Lifetime no. 109252
PTR OR No. 0264398-01/04/2021. Davao de Oro
TIN 939-740-159-000
MCLE Compliance No. IV-0013948 valid until 4/14/2022