REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN CITIES

7TH JUDICIAL REGION
Branch 8, CEBU CITY

PEOPLE OF THE PHILIPPINES,

                                Plaintiff,
                                                             CRIMINAL CASE No. M-CEB-18-01682-CR
                            -versus-     FOR: SLIGHT PHYSICAL INJURIES
 
NERISSA PAZ TABHAN MONTEALTO,
                               Defendant.
x----------------------------------------------------x

URGENT MOTION TO RESET HEARING

DEFENDANT, through the undersigned counsel, unto this Honorable Court, most
respectfully states that:

1) The hearing of this case for the initial presentation of evidence has been set on
November 29, 2018 at 9:00 o’clock in the morning;

2) However, the undersigned counsel hereby regretfully informs the Honorable

Court that she cannot attend the said hearing because she has to attend the
Mandatory Continuing Legal Education on November 28 and November 29 at
Cebu City Sports;

3) The defendant cannot be represented by another lawyer of the firm because of

the fact that the undersigned lawyer’s services have been engaged on a pro bono
basis, as a new requirement given by the Supreme Court of the Philippines;

4) In view of this predicament, the undersigned counsel prays that the scheduled
hearing on November 6, 2018, be reset to another date, subject to the availability
of the Honorable Court’s calendar;

5) This motion is filed with utmost good faith and never intended to delay the
proceedings of the instant case.

WHEREFORE, premises considered, it is respectfully prayed of this Honorable

Court that the schedule hearing on November 29, 2018, be reset to another date, subject
to the availability of the Honorable Court’s calendar.

November 26, 2018, Mandaue City for Cebu City.

REDULA SANCHEZ MONTEALEGRE

BAUZON BRAGAT MENDOZA
& DANLAG-LUIG LAW OFFICES
Counsel for the Defendant
Suites 301-304, C & F Ramirez Building II,
S. B. Cabahug Street, Centro, Mandaue City, Cebu 6014

1
                                                                  By:

                            Katrina N. Pontanar

                               Roll No. 70728
IBP No. 042360 (Cebu City)
MCLE Exempt
Admission to the Bar: April 26, 2018
           

NOTICE OF HEARING

THE CLERK OF COURT

MTCC BRANCH 8, Cebu City

Greetings!

Please submit the foregoing urgent motion for the consideration of the Honorable
Court on November 26, 2018 and set the hearing of the motion on November 29, 2018
at 9:00 in the morning without appearance of counsel and further arguments.

Thank you.

KATRINA N. PONTANAR

Copy furnished:

Atty. Jill Ann P. Gealon

Handling Public Prosecutor
The Office of the City Prosecutor
Chief Fernan Hall Of Justice,
Capitol Compound Road,
Cebu City, 6000 Cebu

          Nolan Genosa Tabhan

          Complainant
          2910 Rosalina Village,
Barangay Labangon
Cebu City, Cebu

     
EXPLANATION OF SERVICE BY MAIL

The undersigned counsel most respectfully manifests that copies of Motion

to Reset Hearing, were served to the above-named addresses by registered mail in lieu
of personal service because of lack of manpower to effect the personal service.

ATTY. KATRINA N. PONTANAR