Republic of the Philippines

MUNICIPAL TRIAL COURT OF JOSE PANGANIBAN

Province of Camarines Norte
Fifth Judicial Region

HEIRS OF SPOUSES LEONARDO ALBIS,

And JUSTINA HIRANG, Rep. By
RAYMOND ALBIS,

Plaintiffs, CIVIL CASE NO. 760

For:
-versus-

JOCELYN Q. ALVAREZ and, EJECTMENT

WILMA C. DIOLATA
Defendants,

x------------------------------------------------x

VERY URGENT MOTION TO RESET HEARING

The above-named Defendants, through undersigned

counsel, unto this Honorable Court, most respectfully aver as
follows:

1. The above-captioned case was reset for Preliminary

Conference/Pre-trial on 3 February 2022 at 1:30 afternoon at
the session hall of the Court, Jose Panganiban, Camarines
Norte;

2. However, the undersigned counsel was directly exposed to

COVID-19 positive person. Currently, she is experiencing dry
cough, colds and body pain. Moreover she still need to undergo
quarantine even if the results will come out negative;

3. Hence, the undersigned counsel respectfully requests to reset

the hearing possibly from the 2nd week of March 2022 onwards.

4. This is to safeguard all the persons in court against the risk

of possible infection.

5. This motion is made in good faith and not to delay the

proceedings but solely for the above reasons.
 PRAYER

WHEREFORE, premises considered, it respectfully prayed

that this motion be granted.

Other relief and remedies, just and equitable, are likewise

prayed for.

2 February 2022, Quezon City, for Jose Panganiban,

Camarines Norte.

ATTY. LUCKY JOY A. DOMING0

Counsel for the Defendant
Philippine Legal Advocates and Research Center Inc.
No. 136 Katipunan Avenue, Barangay St. Ignatius, Quezon City
Roll of Attorney’s No. 74117
PTR NO. 7302565, Bongabon, Nueva Ecija, Janaury 5,2022
IBP O.R. No. 196260, January 5,2022, Nueva Ecija Chapter
E-mail address: luckyjoydomingo@gmail.com/
phillarci@gmail.com
Contact Numbers: 09151973221/ 09752669469

Copy furnished:

Atty. Edward P. Llonillo

Makati City
empresadeabogados@gmail.com