Republic of the Philippines

Third Judicial Region

MUNICIPAL CIRCUIT TRIAL COURT OF BALER-SAN LUIS
Baler, Aurora

PEOPLE OF THE PHILIPPINES,

-versus- Criminal Case No. 3372

For: Falsification of Public

Document
FELIPE S. FERNANDEZ, ET. AL.,
Accused.
x- - - - - - - - - - - - - - - - x
PEOPLE OF THE PHILIPPINES,

-versus- Criminal Case No. 3373

For: Falsification of Public

Document
FELIPE S. FERNANDEZ, ET. AL.,
Accused.
x- - - - - - - - - - - - - - - - x

MOTION TO ADMIT
(Attached is the Comment/Opposition On The Partial Motion For
Reconsideration)

ACCUSED, Grace Erlyn F. Licos (Licos) and Milagros F.

Villaester (Villaester), assisted by the Public Attorney's Office,
through the undersigned Public Attorney, unto this Honorable Court
most respectfully seek, the admission of the attached comment on the
partial motion for reconsideration and further state, that:

1. It was only on November 6, 2023 when the cases of the

former counsel of this case of the Public Attorney’s office
were formally turned over to the undersigned counsel;

2. Due to the voluminous cases being handled by the Office,

the undersigned counsel was not able to find the case file of
this case even after asking help from the office’s staff to look
over the case record but the same was futile;

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 3. Given that this representation had to review and evaluate
carefully the case to fully and ably comment on the motion,
the undersigned, feeling unavailing of the records, went to
the court on January 5, 2024 to read the court’s records of
this case, only then that the undersigned had a glimpse of
the facts of this case;

4. This comment is not intended to undermine the speedy and

proper administration of justice.

5. Thus, it is respectfully pleaded to this Honorable Court that

the herein attached Comment on the Partial Motion for
Reconsideration be admitted and be part of the records of
this case. Likewise, the accused are asking for compassion
and are hoping that a mere delay would merit the
consideration of the Honorable Court.

WHEREFORE, given the foregoing, it is respectfully prayed

unto this Honorable Court that this Comment/Opposition be
ADMITTED and be part of the records of this case.

Other just and equitable reliefs are likewise prayed for.

Respectfully submitted.

January 12, 2024. Baler, Aurora.

Assisted by:

PUBLIC ATTORNEY’S OFFICE

Counsel for the Accused
Department of Justice
PAO Baler District Office
2nd Floor Municipal Legislative,
Municipal Hall of Baler,
Municipality of Baler, Province of Aurora

By:

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 QUEEN JANE TADEJA ALDAVE
Public Attorney I
Roll No. 76089, May 4, 2022
IBP No. O.R. No. 379689; December 29, 2023
Admitted to the Bar on May 4, 2022
queenjanetadeja.aldave2121@gmail.com / 09566971432

NOTICE

THE CLERK OF COURT

MCTC of Baler-San Luis
Baler, Aurora

Greetings!

Please submit the foregoing Comment to the Honorable Court immediately

upon receipt thereof for its consideration and approval without further arguments.

QJTA

Copy furnished:

PROS. SHAUN HASSEN C. OBSUM

Office of the Regional Prosecutor
San Pablo Laguna
obsumshc@yahoo.com

ATTY. THRISTAN B. ESCUDERO

City of Muñoz, Nueva Ecija
escuderolawoffice@gmail.com

EXPLANATION

Pursuant to Section 7, Rule 13 of the revised Rules of Court, a copy of this Comment was
served by electronic mail to the State through Pros. Shaun Hassen Obsum and to the counsel of
the other defendants, Atty. Thristan B. Escudero, due to distance from the Public Attorney’s
Office.

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 QJTA

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