Republic of the Philippines

REGIONAL TRIAL COURT

FOURTH JUDICIAL REGION
ORIENTAL MINDORO
BRANCH 39
Calapan City
-o0o-

CALAPAN LABOR SERVICE CIVIL CASE No. CV-18-7336

DEVELOPMENT COOPERATIVE
(CALSEDECO)Represented by
MANUEL CUBOS,
Plaintiff,

Versus for

MARIA LOURDES L. PALADIN, COLLECTION OF SUM OF

MINA R. ALMENDRAS, MENA MONEY AND DAMAGES
LADRA, LERMA BALMES, JENNIFER
MATALUBOS and LEOVIGILDA E. PIA
Defendants,
x----------------------------------------------------------------------------------------------------------------x

MOTION FOR RECONSIDERATION WITH MOTION TO ADMIT MOTION TO DECLARE

DEFENDANTS IN DEFAULT

Comes now plaintiff, thru the undersigned counsel and unto this Honorable Court most
respectfully avers:

1. That on November 19, 2021 the undersigned received an Order of this Honorable Court
dated November 11, 2021, dismissing without prejudice the instant case for failure to
prosecute for an unreasonable length of time;

2. The undersigned concedes that he lost track of this case mainly because of the
voluminous cases being handled by him for the plaintiff of the same nature. However, his
failure to come up with a pleading was purely inadvertent because he thought that an
answer will be eventually be filed by the defendants;

3. Thereafter, Covid19 came causing lockdowns in the entire country which resulted in the
undersigned’s losing sight of the status of the case;

4. But just like in other collection cases, the plaintiff is bent on prosecuting the instant case
and the undersigned’s failure to file an appropriate pleading was unintentional;

5. In this regard, the undersigned is begging the indulgence of this Honorable Court to
please allow the continuation of the proceedings on this case;

PRAYER

Wherefore premises considered, it is most respectfully prayed of this Honorable Court

that the Order dated November 11, 2021 dismissing the instant case be reconsidered and a new
Order be issued allowing the continuation of the trial of this case. Moreover, it is prayed that the
motion to declare defendants in default be admitted.

Other reliefs just and equitable under the premises are likewise prayed for.
November 24, 2021
Calapan City, Oriental Mindoro

ATTY. JOSEPH RYAN C. APASAN

Counsel for Plaintiff
IBP OR No. 134859
PTR No. 10389162/ Calapan City/ 1-5-2021
IBP Roll No. 56968
MCLE Compliance No. VI-0001337/12-12-16
352 Gozar Street, Camilmil, Calapan City, Oriental Mindoro

Copy furnished:

Copy furnished:

Ma. Lourdes Paladin

Bernardo Lirio Memorial Central School,
Barangay Darasa, Tanuan City, Batangas

Mina R. Almedras
Ulango Elementary School, Barangay Ulango,
Tanuan City, Batangas

Eva M. Marfa
Trapiche Elementary School, Barangay Trapiche,
Tanauan City, Batangas

Jennifer S. Matalubos
Tanauan North Central School, Pres. Laurel Highway,
Tanauan City, Batangas

Leovigilda Pia
____________

Lerma Balmes
____________
NOTICE

Hon. Branch Clark of Court

RTC Branch 39,

Good day! Please submit the foregoing upon receipt hereof for the Honorable Court’s
consideration and please set the hearing of this motion on December 1, 2021 at 8:30 in the
morning (if oral argument is necessary). Thank you.

JOSEPH RYAN C. APASAN

EXPLANATION

Copies of this motion were sent to the defendants thru registered mail due to distance and
lack of personnel of this office to effect personal service. Thank you.

JOSEPH RYAN C. APASAN