Republic of the Philippines

REGIONAL TRIAL COURT

4th JUDICIAL REGION
Branch 66
Tanauan City, Batangas

NATIONAL TRANSMISSION
CORPORATION (TransCo),
Plaintiff,

- versus - SP CV Case No. 18-06-397A

For: Expropriation

RAYMUNDO C. VERGARA married

to SUSANA VERGARA,
Defendant.
x - - - - - - - - - - - - - - - - - - - - - - -- - - - x

SECOND MOTION FOR EXTENSION TO COMPLY

(to Court Order dated 18 September 2019)

PLAINTIFF, National Transmission Corporation (TransCo)

through undersigned counsel, received a copy of Order dated 18
September 2019 on 30 September 2019 requiring it to file a
Manifestation, within five (5) days from receipt or until 05 October
2019, further states that:

1. On 04 October 2019 plaintiff filed a Motion for Extension of

Time to Comply for fifteen (15) days from 05 October 2019 or until 20
October 2019;

2. However, plaintiff’s handling Right-of-Way Officer was

not able to complete its task to verify the exact address of defendant
and identify the possible reason why the summon was unserved due
to equally important voluminous document and number of lots
subject of research and validation from North Luzon, South Luzon,
Visayas and Mindanao, including the subject land of the instant case;

3. Thus, the undersigned handling counsel is constrained to

ask for an additional period of fifteen (15) days from 20 October 2019
or until 04 November 2019 within which to file TransCo’s
manifestation;
 TransCo vs. Leonardo C. Cosa, et al
Page 2 of 4
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4. This motion is made in good faith and is not intended for

delay the present proceedings but mainly for the reasons stated.

RELIEF

ACCORDINGLY, TransCo respectfully prayed to the

Honorable Court that it be given an additional period of 15 days from
20 October 2019 or until 04 November 2019 within which to file
TransCo’s manifestation.

Other equitable reliefs are likewise asked for.

Quezon City for Tanauan City, Batangas, 18 October 2019.

-signatories at the back-

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 TransCo vs. Leonardo C. Cosa, et al
Page 3 of 4
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NATIONAL TRANSMISSION CORPORATION

TRANSCO Main Bldg., Quezon Avenue cor. BIR Road
Diliman, 1128 Quezon City
Tel. No. (02) (7) 902-1500

By:

NOEL Z. DE LEON
General Counsel
IBP No. AR15772438 ; 01/07/19/ Quezon City
Roll of Attorney No. 36660 dated April 1990
MCLE Compliance No. VI-0026339; May 8, 2019

LEON T. TAPEL, JR.

Deputy Legal Counsel
IBP No. 011436; 07/07/18/ PPLM
Roll of Attorney No. 34555 dated May 30, 1987
MCLE Compliance No. VI-0024894; April 17,2019

JAINAL ABIDIN Y. BAHJIN, II

Manager – ROW-Litigation Department
IBP No. 066209; 01/09/19/ Zambasulta
Roll of Attorney No. 56624 dated May 2009
MCLE Compliance No. VI-0021994, March 26, 2019

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 TransCo vs. Leonardo C. Cosa, et al
Page 4 of 4
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NOTICE OF HEARING

The Branch Clerk of Court

RTC Branch 66, Tanauan City
Batangas

Greetings:

Please submit/take notice that the undersigned counsel shall

submit the foregoing Motion for the consideration and approval of
this Honorable Court on 25 October 2019 at 8:30 am without further
arguments and appearance of counsel.

JAINAL ABIDIN Y. BAHJIN, II

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

The foregoing Motion for Extension is being filed and served

by registered mail, personal service not being practicable due to
distance and lack of office personnel.

JAINAL ABIDIN Y. BAHJIN, II