REPUBLIC OF THE PHILIPPINES

SUPREME COURT
Manila

NAVAL CAPT. JAIME A. ORCULLO

(RETIRED), CDR. LORENZ A. TAN,
HM2 LUCIO C. PERAS, LCDR.
CARLOS A. AGRA, LCDR. MIGO D.
PASIA, MR2 NANCY F. PASION,
LCDR. JOHN B. CHAVEZ, PETTY
OFFCR. 1ST CLASS ANTON Q. RION
(RETIRED), and PETTY OFFICER 2ND
CLASS MIL KARL MARC K. PETERS
(RETIRED),
Petitioners,

CA G.R. SP No. 130667

-versus- FOR : Certiorari under Rule
45 of the 1997 Rules of Civil
Procedure

THE HON. JUDGE MARTINI A.

DE CASTRO and SPOUSES RICARDO
AND JACQUELINE ESCANDOR,
Respondents.
x- - - - - - - - - - - - - - - - - - - - - - - - - - - - x

MOTION FOR EXTENSION OF TIME TO FILE PETITION

PETITIONERS, by the undersigned counsel, unto the

Honorable Court of Appeals, most respectfully states the following:

1. The undersigned counsel received the resolution of the

Honorable Court of Appeals denying the Motion for Reconsideration
on this case on February 17, 2020.

2. Thus, the deadline to file the Petition for Review of

Certiorari under Rule 45 is on March 4, 2020.

3. However, due to the pressures of equally urgent

professional work and prior commitments, the undersigned counsel
will not be able to meet the said deadline;
 4. As such, undersigned counsel is constrained to request for
an additional period of 30 days from today within which to file the
Petition. The docket fees and other costs shall be paid upon filing of
this motion.

5. This Motion is not intended for delay but solely due to the

foregoing reasons.

PRAYER
WHEREFORE, Petitioners most respectfully prays of this
Honorable Court that they be given an additional period of 30 days
from today within which to file the Petition for Certiorari under Rule
45 of the Rules of Court.

Davao City, Davao del Sur, March 13, 2020.

SANTOALLA and Associates Law Offices

Counsel for the Defendant
Doors 5 & 6, Tropicana Building,
J.P. Laurel Avenue, Lanang, Davao City
Tel. Nos.: (082) 282-3662
ssantoalla@yahoo.com

By:

Sgd.
ATTY. STEPHANIE M. SANTOALLA
Notary Public for Davao City, Philippines
IBP NO. 071717, 12/12/19, Davao City
PTR NO. 071717, 12/12/19, Davao City
ROLL ATTORNEY NO. 11077
MCLE Comp. No. IV-0004785, 3/2/19
Doors 5 & 6, Tropicana Building,
J.P. Laurel Avenue, Lanang, Davao City

The Executive Clerk

Supreme Court
Manila

Greetings:

Kindly submit the foregoing Motion for the consideration and

approval of the Honorable Supreme Court immediately upon receipt
hereof.

Sgd.
ATTY. STEPHANIE M. SANTOALLA

Copy furnished:

Hon. Judge Josefina E. Siscar

Presiding Judge
Regional Trial Court
Branch 55, Manila

Hon. Court of Appeals

Padre Faura, Manila

Atty. Martha A. Solaiman

Counsel of the Respondents spouses Escandor
2/F, ABC Building, Damosa Complex
Lanang, Davao City

EXPLANATION
(Pursuant to Section 5, 7, & 11 Rule 13, 1997 Rules of Civil
Procedure)

The foregoing Motion for Extension of Time is served by

registered mail as personal service is not practical because of time,
distance and manpower constraints.

Sgd.
ATTY. STEPHANIE M. SANTOALLA