Republic of the Philippines

REGIONAL TRIAL COURT

10th Judicial Region
Branch 17
Cagayan de Oro City

MERCADAL ENTERPRISES CIVIL CASE NO. 2009-059

Rep. By: ERNIE MERCADAL,
Plaintiff, FOR: COLLECTION OF SUM
OF MONEY WITH PRAYER
FOR PRELIMINARY
ATTACHMENT
-versus-

SPS. ANTONIO & EDNA

GARMENDIA,
Defendants.
x-----------------------------------------/

MOTION FOR RECONSTITUTION OF JUDICIAL

RECORDS OF THE ABOVE-ENTITILED CASE

COME NOW Plaintiffs, by counsel, unto the honorable

Court most respectfully avers:

1. That the above-entitled case was filed by herein plaintiffs

on March 5, 2009 with docket fees already paid; while
defendants filed their answer with affirmative defense on
April 3, 2009;

2. That defendants, through counsel, already submitted

their formal offer of exhibits and memorandum on
November 11, 2013 and April 14, 2014, respectively;

3. That the case was already submitted for decision;

4. That unfortunately on January 31, 2015, the entire Hall

of Justice building was razed to the ground thereby
destroying all courts’ records inside the same including
the records of the above-entitled case, thus the need to
reconstitute the same;
 PRAYER

WHEREFORE, premises considered, herein counsel

respectfully prays that records of the above-entitled case be
reconstituted using the available and genuine records of the
plaintiffs’s counsel which are hereto attached for the
Honorable Court’s examination and if found true and
sufficient that a resolution be rendered in accordance thereto.

Undersigned counsel also prays for such other reliefs just

and equitable in the premises.

Cagayan de Oro City, February 16, 2015.

EDGAR S. CABANLAS
Counsel for Petitioners
CABANLAS, RESMA & RANA LAW OFFICE
101-E, 2nd Floor, Velez Bldg.,
Corrales Avenue, Cagayan de Oro City
ATTY’S ROLL No. 30264, March 9, 1980
PTR No. 2709771A (12-23-14)
IBP No. 875101 (12-23-14)
Tin No. 114-721-172
MCLE IV – No. 002712
Cellphone No. 09188084555
Copy furnished:

ATTY. JOCELYN A. LOOD

GP Adaza., Hayes-Rizal Streets
Cagayan de Oro City

- NOTICE OF HEARING -

THE CLERK OF COURT

RTC, Branch 17
Hall of Justice, Cagayan de Oro City

ATTY. JOCELYN A. LOOD

GP Adaza., Hayes-Rizal Streets
Cagayan de Oro City
Greetings:

Please be informed that the foregoing motion shall be

submitted to the Honorable Court immediately upon receipt
hereof for approval and consideration sans oral argument and
presence of counsel.

EDGAR S. CABANLAS