REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
TAGUIG CITY

BRANCH 69

JEFFREY HIGINO N. SANTOS, JDRC CASE NO. 106

Petitioner, FOR: Declaration of Nullity of
Marriage; Dissolution of the Regime
- versus - of Absolute Community of Property;
Joint Exercise of Parental Authority
MA. AISSA CABACCANG- over their Child
SANTOS,
Respondent.
x---------------------------------------x

MOTION TO RESET
-----------------------------

Petitioner, JEFFREY HIGINO N. SANTOS, by counsel and unto this

Honorable Court, respectfully states that:

1. Petitioner is scheduled to present its last witness, Dr. Nedy L.

Tayag, on 24 October 2018 at 8:30am.

2. However, due to her busy schedule, Dr. Tayag will not be able
to attend the said hearing date. Unfortunately, Dr. Tayag is also not available
on the additional setting on 28 November 2018.

3. Dr. Tayag committed to make herself available on 21 November

2018 at 8:30am.

4. Considering the foregoing, Petitioner prays that the scheduled

hearing dates on 24 October 2018 and 28 November 2018, both at 8:30am,
be cancelled. Petitioner also prays that this case be set for hearing on 21
November 2018 at 8:30am.

5. This motion is not intended for delay and is solely sought for
the reasons herein stated.
 Motion to Reset
“Jeffrey Higino Santos vs. Ma. Aissa Santos”
JDRC CASE NO. 106
Page 2 of 4

PRAYER

WHEREFORE, it is most respectfully prayed that the scheduled

hearing dates on 24 October 2018 and 28 November 2018, both at 8:30am,
be cancelled, and that this case be set for hearing on 21 November 2018 at
8:30am.

OTHER RELIEFS, just and equitable under the premises, are likewise
prayed for.

Pasig City for Taguig City, 05 October 2018.

EDGAR V. MENDOZA
PTR No. 2575174/01-12-17/Pasig City
IBP Lifetime Member No. 00813/11-15-96
MCLE Compliance No. V-0018028/04-08-16
Roll of Attorney No. 36516

MONFREY C. LUGO
PTR No. 2575177/01-12-17/Pasig City
IBP Receipt No. 1069180/01-20-17/Isabela
MCLE Compliance No. V-0013119/01-12-16
Roll of Attorney No. 61143

CHRISTINE E. OCAMPO-DE GUZMAN

PTR No. 2575176/01-12-17/Pasig City
IBP No.1069181/01-20-17/RSM
MCLE Compliance No. V-0013128/01-12-16
Roll of Atty. No. 60463

CHARMAINE P. MEJIA
PTR No. 36363242/10-11-17/Pasig City
IBP Lifetime Member No.016825/RSM
MCLE Compliance No.1
Roll of Atty. No. 69856

GERARD EMMANUEL V. TAYAO

PTR No. 4141333/03-01-18/Pasig City
IBP Receipt No. 034174/ 03-01-18/Makati
MCLE Compliance No.2
Roll Atty. No. 70407

1
Recently passed the 2016 Bar Examinations and signed the Roll of Attorneys on 1 June 2017.

2
Recently passed the 2016 Bar Examinations and signed the Roll of Attorneys on 13 June 2017.
 Motion to Reset
“Jeffrey Higino Santos vs. Ma. Aissa Santos”
JDRC CASE NO. 106
Page 3 of 4

MENDOZA NAVARRO-MENDOZA & PARTNERS LAW OFFICES

Counsel for Petitioner
Units 205 & 501, Amberland Plaza
Doña Julia Vargas Ave. & Jade Drive
Ortigas Center, 1605 Pasig City, Metro Manila
Trunk line: 635-5559

THE CLERK OF COURT

RTC TAGUIG BRANCH 69

OFFICE OF THE SOLICITOR GENERAL

OFFICE OF THE CITY PROSECUTOR

Taguig City

PATRICIO L. BONCAYAO, JR.

Counsel for Respondent

Greetings:
Please take notice that the undersigned counsel will submit for the
resolution of this Honorable Court the foregoing Motion at its earliest
convenience without need of further oral argument.

GERARD EMMANUEL V. TAYAO

EXPLANATION

(Pursuant to Section 11, Rule 13 of the 1997 Rules of Civil Procedure)

This Motion is being filed with this Honorable Court and served on
the other parties by registered mail/licensed courier for reasons of
convenience and expediency, personal service being impracticable due to
time, distance and personnel constraints. (Please disregard if filing or
service was effected personally.)

GERARD EMMANUEL V. TAYAO

 Motion to Reset
“Jeffrey Higino Santos vs. Ma. Aissa Santos”
JDRC CASE NO. 106
Page 4 of 4

Copy furnished:

OFFICE OF THE SOLICITOR GENERAL

132 Amorsolo Street, Legaspi Village
Makati City

OFFICE OF THE CITY PROSECUTOR

Taguig City

PATRICIO L. BONCAYAO, JR.

Counsel for Respondent
2F Ancestry Bldg., Rotonda,
Alabang, Muntinlupa City