Republic of the Philippines

DEPARTMENT OF JUSTICE
OFFICE OF THE PROVINCIAL PROSECUTOR
Province of Palawan
Puerto Princesa City

PEOPLE OF THE PHILIPPINES NPS NO. IV-08-INV-20E-0221

Plaintiff,
FOR:
-versus-

BENEDICTO HORTALEZA alias BEBOT, RENATO L. “PRESIDENTIAL DECREE NO. 1602

ABRINA, RICKY B. MATADOS, RENE B. BESONIA, (ILLEGAL GAMBLING) AS AMENDED
RAFAEL O. CONDESA JR, MARK LINDON C. PATARAY, BY R.A. 9287
WALTER R. CANALES, GERRY GERMAN J. BADAJOS,
RENANTE S. PALAY, CHRISTOPHER A. PERALTA,
JERWIN T. ARENAJO, LEOVEN R. BEGUINA, FERNANDO
R. TEODOCIO, REGIE F. ULSON, CHRISTIAN F. ULSON,
ERNESTO C. PALCES, PEDRO P. DELA CRUZ JR and
JOHN DOES,
Accused.
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MOTION FOR EXTENSION OF TIME TO FILE COUNTER-AFFIDAVIT

RESPONDENT PEDRO P. DELA CRUZ, through counsel, unto the

Honorable Office of the Provincial Prosecutor, respectfully states:

1. On June 22, 2020, the respondent received the sub poena in

relation to the above-captioned complaint directing him to submit
counter-affidavit within ten (10) days from such date of receipt. His
last day to submit counter-affidavit is on July 1, 2020;

2. Respondent is a resident of Barangay Tinintinan, Araceli, Palawan

where no legal counsel is available to help the respondent prepare
the counter-affidavit. This is complicated by the enforced general
community quarantine that restricts mobility or travel outside of
the municipality;

3. The undersigned counsel just arrived in town for other purpose and
help is sought only for the purpose of filing this motion to extend,
hence, it constrains the respondent to request for another ten (10)
days extension to submit counter-affidavit to the above-captioned
complaint;

4. This motion is not intended to delay the proceedings in the

preliminary investigation of the complaint, but is resorted to only
due to the above-cited reasons.
 PRAYER

WHEREFORE, in view of the foregoing and in the interest of justice,

it is most respectfully prayed that respondent be given an extension of
ten (10) days from July 1, 2020 to July 10, 2020 within which to submit
counter-affidavit to the above- titled complaint.

Other reliefs and remedies which are just and equitable under the
premises are likewise prayed for.

Poblacion, Araceli, Palawan, July 1, 2020

BETHEL FAITH G.
BERONIO
ROLL NO. 72329
IBP-Palawan