Republic of the Philippines

REGIONAL TRIAL COURT

9th Judicial Region
BRANCH 19
Pagadian City

IN RE: EX-PARTE PETITION FOR MISC. CASE NO. 010-2K15

ISSUANCE OF A WRIT OF POSSESSION

PHILIPPINE NATIONAL BANK

Petitioner
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URGENT MOTION FOR RESETTING/POSPTPONEMENT

COMES NOW, respondent, through counsel and unto this Honorable Court,
respectfully submits this instant motion and in support thereof, it further avers;

1. This case is scheduled for hearing on June 19, 2017, at 8:30 oclock in the
morning;
2. Respondent husband Jose Ladlad Sr. passed away last January 30, 2017, and
considering that it was the latter who actively participated the herein case during
his lifetime, his surviving spouse Emsa B. Ladlad, also herein respondent, had to
look all the records, documents and other pertinent papers which are necessary
for her opposition to issuance of the writ of possession. Hence, counsel is praying
for the resetting of the instant case from JUNE 19, 2017, to the next available
calendar date of the Honorable Court;

3. This instant motion is not intended to delay the proceeding of the above-entitled
case but demanded by the circumstances afore-mentioned;

WHEREFORE, premises considered, it is most respectfully prayed that the

hearing of above-entitled case be reset from JUNE 19, 2017, to the next available
calendar date of the Honorable Court.

Respectfully submitted this 15th day of June 2017, at Pagadian City,

Zamboanga del Sur, Philippines.

ATTY. FELIX M. ESCALANTE, JR.

Counsel for the Plaintiffs
Attorneys Roll No. 57655
IBP No. 1039460, 01/03/17
Issued at Pagadian City
PTR No. 0166655, 01/03/17
Issued at Pagadian City
MCLE Compliance No. IV-0014312
Issued on March 21, 2013
 MCLE Compliance V: 0005045
Issued on December 18, 2014 and
Valid until April 14, 2019
Email ad: pgochief@yahoo.com
0917-623-0775

NOTICE
ATTY. IAN ANTHONY P. SAPAYAN
SAPAYAN LIM ALVAREZ amd LIGUTA LAW OFFICE
Unit 2B, Sail Center Commercial Complex
Joe L. Briones Street, North Reclamation Area
Cebu City

ATTENTION: The Branch Clerk of Court

RTC Branch 19

G R E E T I N G S!

Upon receipt, please submit the foregoing motion for resetting/postponement

for the consideration of this Honorable Commission, sans, without further
arguments.

ATTY. FELIX M. ESCALANTE JR.

Copy Furnished: Via registered mail with return card due to distance between
Pagadian City to Cebu City.

ATTY. IAN ANTHONY P. SAPAYAN

SAPAYAN LIM ALVAREZ amd LIGUTA LAW OFFICE
Unit 2B, Sail Center Commercial Complex
Joe L. Briones Street, North Reclamation Area
Cebu City

CERTIFICATION/EXPLANATION

I HEREBY CERTIFY that copy of the Motion for Resetting/Postponement is

sent To Atty. Ian Anthony P. Sapayan, with office address at Unit 2b, Sail Center
Commercial Complex, Joel L. Briones Street, North Reclamation Area, Cebu City,
via registered mail with return card due to distance between Pagadian City to Cebu
City

ATTY. FELIX M. ESCALANTE JR.