Republic of the Philippines

METROPOLITAN TRIAL COURT

National Capital Judicial Region
Branch CXXXIII (133), Quezon City
th
4 Flr. Hall of Justice, Diliman, Quezon City
E-mail: Metc1qzn133@judicary.gov.ph
Tel No. (02) 8924 8544 or 09150059096

People of the Philippines,

Plaintiff,
Criminal Case No: 22-13839-CR
For: UNJUST VEXATION
ELINO PADILLA y ALBINO, SR.,
Defendants.
x---------------------------------------------------------x

MOTION TO RESET
PRE-TRIAL HEARING
Now comes accused ELINO PADILLA y ALBINO, SR. through counsel and
unto this Honorable Court, most respectfully states that:

1. I filed before this Honorable Court a formal entry of appearance, dated

May 7, 2023;

2. The pre-trial proper of the above-captioned case is set on May 15,

2023, at 8 o’clock in the morning;

3. However, I had a scheduled hearing to attend in another court which

was already on May 15, 2023, long before the accused secured my
service, which is in conflict with the above-scheduled pre-trial hearing;

1. Attached herewith is the copy of the Order issued by the RTC of

Quezon City, Branch as ANNEX “A” to “A-2”.

2. In this regard, the undersigned counsel without wanting to delay this

case, is constrained to respectfully request this Honorable Court to
reset the scheduled hearing of the above-captioned case to another
date as may be convenient to the schedule of this Honorable Court and
to the other party; Also, this representation may be given ample time
to study the case and the avails of the opportunity, if any, to explore
the strong possibility of settlement of this case.

3. This motion is made in good faith and not intended to delay any
further the proceedings of this case but merely because of the conflict
in schedule.
 WHEREFORE, it is hereby respectfully prayed from this Honorable
Court that the pre-trial hearing of the instant case be reset to another date
as may be convenient to the schedule of this Honorable Court.

Other reliefs, just and equitable under the premises are likewise
prayed for.

May 14, 2023, Quezon City, Philippines.

ATTY. PATRIO T. SEÑERES, JR

Counsel for the private complainant
Roll No. 79983, 18 May 2022
PTR No. 4104634 D; 01/13/2023; Quezon City
IBP NO.222458 D, 5/19/2022, Quezon City
MCLE VIII Certificate No. 0000990, December 2, 2022
89520924 / 09685543245 / 09152520401
email Address: atty.patseneres@yahoo.com
475 Col. Bonny Serrano Ave., Brgy San Roque, Corner 5th Camarilla
St., Murphy, Cubao, Quezon City