REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 112
PASAY CITY

EDWIN D. SUPELANA
Plaintiff,

VS. Civil Case No. R-PSY-17-24256-CV

For: SUM OF MONEY

MARLO G. RAYMUNDO
Defendant
X------------------------------------------------------------------------X

URGENT MOTION FOR RECONSIDERATION

The Plaintiff through the undersigned counsel received today the copy of this
Court’s Order dated 12 September 2022 – and for this the Plaintiff moves to
reconsider and set aside the said Order for the following grounds:

1. The notice of appeal is filed out of time. The notice of appeal is filed on
September 2, 2022, or later, and the assailed Decision was received by
the Defendant on August 16, 2022. In the first place the filing of the notice
of appeal is not the proper pleading under the Revised Rules on Civil
Procedure:
2. This Court exercised its appellate jurisdiction over this case and under
Rule 42, the Defendant should have filed a Verified Petition for Review
with the Court of Appeals within 15 days from the notice of Decision;
3. Again, aside from filing a wrong pleading, the Defendant has filed the
same beyond 15 days from August 16, 2022. They should have filed a
Verified Petition for Review with the Court of Appeals on or before August
31, 2022.

PRAYER

WHEREFORE, it is prayed that the Appeal of the Defendant be considered

filed out of time and the instant case be considered final and executory. Other relief
just and equitable is likewise prayed for.

October 4, 2022, Parañaque City for Pasay City.