Republic of the Philippines

REGIONAL TRIAL COURT

FOURTH JUDICIAL REGION
Branch 99, Antipolo City
(Seated at Taytay, Rizal)
rtc1ant099@judiciary.gov.ph

SPS. BENJAMIN BARRUEL

AND CARMELA BARRUEL,
Rep. by Atty. Aldrin G.
Penaflor,
Plaintiff,
Civil Case No.19-11921
-versus-
For: Recovery of Possession

SPS. JESUS AQUINO AND

ONORIDAD AQUINO and all
persons claiming rights
under them.
Defendants.
x--------------------------------------x

MOTION TO RESET
DEFENDANTS, through counsel and unto this
Honorable Court, most respectfully states that:
1. The Honorable Court set the Pre-Trial proper of this case
on 05 November 2021 at 8:30 am pursuant to a Notice of Pre-Trial
dated 28 July 2021.

2. Unfortunately, undersigned counsels cannot appear

on the said date due to conflict in schedule. Particularly, the lead
counsel has to appear in another hearing which was set earlier, before
the Municipal Trial Court of San Felipe, Zambales at 8:30 a.m. in the
case entitled People of the Philippines vs. Carlos Sahagun docketed
as Crim. Case No. 5721.

3. Her co-counsel as well on the said date has prior

engagement she needs to attend to which is of equal importance.

3. Defendants, thus, respectfully moves that the Pre-Trial set

on 05 November 2021 at 8:30 am be reset to the additional date set
by this Honorable Court on 26 November 2021 at 8:30 am.

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 4. This motion is not intended to delay the proceedings of the
Honorable Court but is being interposed solely for the above-stated
reasons.
PRAYER

WHEREFORE, premises considered, it is respectfully prayed

of this Honorable Court that the Pre-Trial set on 05 November 2021
at 8:30am be reset on 26 November 2021 at 8:30 am.

All other reliefs just and equitable are likewise prayed for.

RESPECTFULLY SUBMITTED.
Cainta for Antipolo City, 25 October 2021.

Counsel for Defendants:

JARENE EURICE C. CAMBALIZA

PTR No. 10665323;1/5/2021; Zambales
IBP No. 141426; 1/5/2021; Quezon City
Roll of Attorneys No. 67877
MCLE Compliance No. VI-0014841, 11/15/2018
Mobile No. (0917) 846-3686
Email: jecambaliza@gmail.com
Address: 0642 Bonifacio Avenue (Rizal Ave.,),
Cainta, 1900 Rizal

NOREEN JOYCE E. AQUINO

PTR NO. 5174392; 01/07/19; Pasig City
IBP Lifetime No. 016378
Roll of Attorney’s No. 68618
MCLE Compliance No. VI-0014842
Mobile No: 09171524303
Email: aquino.nje@gmail.com
Address: 5 J. Asilo St. Taytay, Rizal

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Copy furnished, Request and Notice of Hearing:

HON. CLERK OF COURT

RTC, Branch 99, Antipolo City
(Seated at Taytay, Rizal)

ATTY. ALDRIN G. PENAFLOR

Counsel for Plaintiffs
2nd Floor, Mateo Building
183 Rizal Ave., Brgy. San Juan
Taytay, Rizal

Greetings:

Please take notice that the foregoing Motion To Reset will be

submitted for the consideration of the Honorable Court immediately
upon receipt, sans appearance of counsel.

JARENE EURICE C. CAMBALIZA

EXPLANATION FOR FILING

BY REGISTERED MAIL/ COURIER

In compliance with Rule 13, Section 11 of the Rules of Court,

counsel respectfully explains that this Motion To Reset will be filed by
registered mail due distance and time constraints, and the temporary
unavailability of office personnel to effect personal service.

JARENE EURICE C. CAMBALIZA