Republic of the Philippines

MUNICIPAL TRIAL COURT

Third Judicial Region
Zaragoza, Nueva Ecija

PATRICK G. MONTELIBANO AND

MARY ANN REYES MONTELIBANO, CIVIL CASE No._
Plaintiffs, For UNLAWFUL
DETAINER with
-versus- DAMAGES and with
Prayer for Temporary
LEONCIO CAMUS & Restraining Order and
ISAGANI CAMUS (LOT 23) Preliminary Mandatory
FERNANDO DANTES (LOT 18), Injuction
REYNALDO DELA CRUZ &
LUZVIMINDA DELA CRUZ AKA
LUSVIMINDA C. FRESTO (LOT 19),
RODOLFO DELA CRUZ (LOT 20),
FEDERICO GELACIO (LOT 6),
CEFERINO REYES (LOT 3),
MARCOS RODRIGUEZ (LOT 14),
BONIFACIO SALONGA (LOT 10),
CELESTINO SANTOS (LOT 7), and
BEN BASILIO SARONDO (LOT 9),

Defendants.
x……………………………………………..x

MANIFESTATION1 WITH
EX PARTE PRAYER TO SET HEARING ON THE
APPLICATION FOR TRO AND PRELIMINARY
MANDATORY INJUNCTION ON 30 MAY 2018

COMES NOW the undersigned counsel for the Plaintiff and to this
Honorable Court most respectfully states:

1. Plaintiffs Spouses PATRICK G. MONTELIBANO and MARY ANN

REYES MONTELIBANO are currently outside the Philippines. As of
press time, both Plaintiffs are in Osaka, Japan with their children
and their travel abroad has been long planned and scheduled as
early as last year and long before they filed the present
Complaint against the Defendants.

2. For the record, Plaintiffs Spouses put off their travel for a week
when the Complaint was filed in anticipation of the immediate
and summary hearing on the application for TRO.

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Via E-mail from haroldaramos@icloud.com to mtc_zaragozanuevaecija@yahoo.com

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 3. It is the understanding of the Plaintiff’s counsel that last week,
however, the Honorable Court cannot proceed immediately to
tackle the application for TRO as the Honorable Judge was then
indisposed and they are relieved and very much pleased to know
that she has now fully recovered from sickness and, point in fact,
Plaintiffs are very much aware of the stress and pressures that
the Honorable Lady Judge has to contend by reason of her work.

4. On this score, Plaintiffs’ counsel now respectfully seek latitude

and a little leeway from the Honorable Court due also to his tight
schedules. He was only informed on a very short notice and only
today (shortly before noon) that a hearing is set at 10:00 am
tomorrow to resolve the application for TRO.

5. Too, Plaintiffs profusely apologize for their inability and, nay,

physical impossibility for them to heed the Court’s Order setting
the hearing on the TRO tomorrow considering that they are still
out of the country.

6. We hasten to add that there is no deliberate intention to delay

the hearing and, on the contrary, the Plaintiffs are very much
anxious if and when the TRO will be issued due to the continuing
actions of the Defendants in making wire fences and enclosures
on the property belonging to the Plaintiffs.

PRAYER

BECAUSE OF THE FOREGOING PREMISES, may we please ask that

the Honorable Court’s hearing on the TRO originally scheduled tomorrow be
cancelled and a new setting be granted and preferably at ten o’clock (10:00)
in the morning of May 30, 2018.

RESPECTFULLY SUBMITTED this 17th day of May 2018 at Zaragoza,

Nueva Ecija, Philippines.

________________________
ATTY. HAROLD A. RAMOS
Counsel for the Plaintiffs
Roll of Attorneys No. 45195; Issued on May 5, 2000
IBP Receipt No.040755; Issued on January 31, 2018
At Dona Julia Vargas Avenue, Ortigas Center, Pasig City, Philippines
IBP Ilocos Norte Chapter
MCLE Compliance No. V-0025365 (Valid Until April 14, 2019)
PTR No. BGT5537907; Issued on January 25, 2018
At La Trinidad, Benguet, Philippines

033 Sitio Dapiting

Barangay Alapang, La Trinidad, Benguet
e-mail: haroldaramos@icloud.com
Contact No.: 639206856489

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