REPUBLIC OF THE PHILIPPINES

SUPREME COURT
MANILA

LEGRES MARKETING CORPORATION,

Petitioner,

-VERSUS-
S.C. G.R. No. 233516
FOR: Petition for Review on Certiorari

WRITING DEVELOPMENT CORPORATION

Respondent.
X------------------------------------------------------------X

MOTION FOR RECONSIDERATION

COMES NOW, the Petitioner by undersigned counsel, unto this

Honorable Supreme Court, most reverently avers:

a. That Petitioner desires for a Petition for Review on Certiorari on the

case which was decided by the 19th Division of the Court of Appeals, now
docketed as S.C. G.R. No. 233516;

b. That a decision was rendered by the said Division of the Court of

Appeals on 28 November 2014, and a copy of the said decision was received
by the counsel of the Petitioner on 29 January 2015;

c. That Petitioner’s counsel then filed a Motion for Reconsideration

dated 11 February 2015, which was subsequently assailed through a
Resolution denying Petitioner’s Motion for Reconsideration dated 15
January 2016, a copy of which was received by the Petitioner’s counsel on
27 January 2016;

d. That on 11 February 2016, Petitioner’s counsel filed a Motion for

Extension to file a Petition for Review on Certiorari with the First Division
of the Honorable Supreme Court, Undersigned counsel anticipates the
constraint of time on the part of the Petitioner and counsel to complete and
file said Petition within the allowable reglementary period due to the heavy
workloads that this counsel is attending to, hence, a prayer for extension of
thirty (30) days from 11 February 2016 or until 12 March 2016;

e. That on 14 March 2016, Petitioner through counsel filed the Petition

for Review on Certiorari dated 13 March 2016;

f. That on 22 September 2016, a notice from the Honorable Supreme

Court dated 31 August 2016 was received by Petitioner’s counsel, stating
that Petition for Review on Certiorari was denied due to late filing pursuant
to Sec. 5(a), Rule 56 of the 1997 Rules of Civil Procedure, therefore this
motion.

g. That Petitioner’s counsel humbly submits with utmost respect to this

Honorable Supreme Court that said petition was not filed out of given time
in consonance with Section 1 Rule 22 of the Rules of Court, to wit:

“Section 1. How to compute time. In computing any period of time

prescribed or allowed by these Rules, or by order of the court, or by
any applicable statute, the day of the act or event from which the
designated period of time begins to run is to be excluded and the date
of performance included. If the last day of the period, as thus
computed, falls on a Saturday, a Sunday, or a legal holiday in the
place where the court sits, the time shall not run until the next working
day.”

h. That as to this case, the last day of filing for the Petition for Review
on Certiorari is on 12 March 2016 which is a Saturday and as provided in the
abovementioned Section, said Petition would still be in the coverage of the
Motion for Extension prayed for, given that the last day of filing would be
the next working day which is 14 March 2016.

PRAYER

WHEREFORE, it is most respectfully beseeched to the First

Division of this Honorable Supreme Court that the Resolution denying the
Petition for Review on Certiorari dated 31 August 2016 be set aside and a
new one be come into in reconsideration of the Petition for Review on
Certiorari.
 Other reliefs just and equitable are likewise sought.

Manila, Philippines. 29 September 2016.

HANS CHRISTIAN ROMULO B. CHAVEZ

Counsel for the Petitioner
Manila City, Philippines

CC:

Writing Development Corpration

Unit 5 Medical Plaza Sunware Bldg.,
San Miguel Ave., Ortigas Center, Pasig City

Court of Appeals
Cebu City, Formerly Nineteenth Division