Republic of the Philippines

Department of Justice
 NATIONAL PROSECUTION OFFICE
OFFICE OF THE PROVINCIAL PROSECUTION-LEYTE
OPP Sub-Office, MENRO Bldg. LGU Compound Abuyog, Leyte

PCA, MINERVA LANGCO

                                            Plaintiff,

                    - versus -                 NPS Docket No. VIII-029-INV-23A-011

DONATO MERCADO JR.,

                                       Defendant.
x-------------------------------------------x

MOTION FOR EXTENSION OF TIME

TO FILE COUNTER AFFIDAVIT

          Defendant, by counsel, respectfully alleges that:

1.    On February 1, 2023, he received a copy of the plaintiff's Offer of Evidence dated January
26, 2023. Hence, pursuant to the order of the Public Prosecutor that on February 1, 2023
to file a Counter Affidavit upon the receipt of the, defendant has ten (10) days or until
February 11, 2023 within which to file its Answer to the same;

2.    However, due to volume and pressure of work, coupled with other equally important and
urgent professional commitments, the undersigned counsel cannot complete the said
Counter Affidavit with necessary evidences within the period required and will need an
additional ten (10) days from February 11, 2023 or until February 21, 2023 within which
to do so; 

3.    This motion is being filed due to the reason above-stated and not for the purpose of delaying
the instant case.  

         WHEREFORE, defendant prays that he be granted an additional ten (10) days from
February 11, 2023 or until February 21, 2023 within which to submit a Counter Affidavit
with the necessary evidences.
  
Tacloban City, Philippines. February 3, 2023.