REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
ILOILO CITY

BENJAMIN PEDROSA, JR.,

Complainant/s,

NPS DOCKET NO.:VI-10-INV-19G-00475

-Versus-
FOR: ATTEMPTED MURDER
GRAVE THREAT

ROGER BACALANGCO,
Respondent/s.
X------------------- -----x

MOTION FOR EXTENSION OF TIME

[TO: FILE COUNTER-AFFIDAVIT]

COMES NOW the undersigned and unto this Honorable Office, most
respectfully states: That,

1. Herein respondent received a copy of the subpoena in the above

captioned case last March 02, 2019 wherein he was ordered to
file his counter-affidavit on August 05, 2019;

2. That the respondent upon learning of the above captioned case

has tried to look for a counsel to assist him in this case;

3. That it was only last August 02, 2019 that the undersigned
counsel was engaged by respondent;

4. From the engagement of the undersigned counsel up to this

time, the undersigned has been seriously taking effort to prepare
the counter-affidavit of the accused as well as collating all
necessary evidence to be attached to the said counter-affidavit
that up to this time the same is not yet complete and ready;

5. Thus, due to the above mentioned reasons, undersigned and

respondent is constrained to ask for an extension of time to file
respondent’s counter-affidavit of at least Ten (10) days from
today, August 05, 2019 or until August 15, 2019, in order to
prepare and submit a well written Counter-Affidavit;

6. The respondent has a clear and meritorious case that truly

requires the resolution of the Honorable Court based on its
1|Page
 merits, and this motion was only filed due to the reason as
afore-stated and not for the purpose of delaying the instant case;

ENTRY OF APPEARANCE

7. The undersigned counsel is most respectfully entering his

appearance as counsel for herein respondent who has an office
address at Ground Floor, CBCP Bldg., Fajardo St., Jaro, Iloilo
City 5000 and telephone number (033) 320-0528. Thus, in view
of the said entry of appearance, the undersigned counsel most
respectfully requests that all pleadings, orders, notices and
resolutions in the above-entitled case be furnished to him at his
address herein stated; and

8. That in view of the urgency of the matter, the present motion is

immediately submitted for resolution and the same is exempted
from the 3-day notice rule.

PRAYER

WHEREFORE, Respondent, most respectfully prays of the above

captioned Honorable Court that it be granted an extension of Ten (10) days
from today, August 05, 2019, to August 15, 2019, in order to prepare and
submit a well written Counter-Affidavit. Furthermore, it is likewise prayed
that the entry of appearance of the undersigned counsel be duly noted and
that he be furnished with notices, resolution and other processes in relation
to this case.

Accused likewise prays for other relief and remedies which are just
and proper under the premises.

Iloilo City, Philippines, August 05, 2019.

THE LAW FIRM OF LAURON DELOS REYES AND PARTNERS

Counsel for the Respondent
Ground Floor, CBCP Bldg.,
Fajardo St., Jaro, Iloilo City 5000
(033) 320-0528
By:

2|Page
 EDGAR JANINE L. PESTAŃO
Counsel for the Respondent
Roll No. 53123
PTR No. 6421698 Issued on 1/3/2019/ Iloilo City
IBP No.097551 Issued on 1/4/2019 at Pasig City
Date of Admission – April 26, 2007
MCLE Compliance VI No. 0010122 – July 04, 2018

NOTICE

ASST. CITY. PROS. KAREEN P. DELA CRUZ

Investigating Prosecutor

Greetings.

We are submitting the foregoing motion for your immediate approval

and consideration upon receipt hereof without further oral arguments.

EDGAR JANINE L. PESTAŃO

Copy furnished:

Atty. Raymund Anas

Counsel for the Complainant
20 Hipodromo Ext., Delgado St. Ext. Iloilo City
By:________________________________
Date:______________________________

Greetings.

Please be notified that the undersigned will submit the foregoing

motion for the immediate approval and consideration of the Honorable
Prosecutor upon receipt hereof without further oral arguments.

EDGAR JANINE L. PESTAŃO

EXPLANATION
Copy of this motion was served to respondent through registered mail
due to lack of person to effect personal service and in order to avoid
personal confrontation which may lead to any untoward incident.
3|Page