Republic of the Philippines

REGIONAL TRIAL COURT

Fourth Judicial Region
Branch 22, Imus City, Cavite

IN RE: IN THE MATTER OF THE

PETITION FOR ADOPTION OF
M I N O R H YA C I N T H E L I S H A
CERCADO YUMANG,

S. P. PROC. NO. 1718-18

SPOUSES MICHAEL AND MYLA

REAL,
Petitioners,

x———————————————x

MOTION TO SET HEARING VIA

VIDEO CONFERENCE

Petitioners through the undersigned counsel and unto this

Honorable Court, most respectfully aver the following:

1. That the continuation for the presentation of Petitioners’

evidence is set for hearing on September 7, 2020 at 8:30 a.m.;

2. I have received reliable information that a fellow lawyer based

in Cavite tested positive for Covid-19 which he could have possibly
contracted while appearing in various courts in the province. Having
gained this, one cannot help but fear for one’s life in view of the
unavailability of vaccines for Covid-19;
 3. The undersigned counsel, who is already fifty (50) years old
belong to the immunocompromised sector and fears for her life in view
of the Covid-19 pandemic. She prohibits going out of the premises of
her house to limit exposure, as much as possible;

4. In the same manner that the prospective adoptee, HYACINTH

ELISHA C. YUMANG, has a prevailing medical condition. She is
afflicted with asthma, making her vulnerable to contract Covid-19.

5. It is the fervent request of this representation that the hearing

set for this case and the subsequent hearings be conducted via video
conferencing so as to protect all parties concerned - the court
personnel, the Honorable Judge, the Honorable Prosecutor, the
Petitioners in light of the present Corona virus 19 panemic affecting
the entire world.

PRAYER

Wherefore, premises considered, it is most respectfully prayed

that the hearing set for September 7, 2020 at 8:30 a.m. and the
subsequent hearings that are necessary for this case be set through
video conference to better serve the best interest of all the parties
concerned.

All other reliefs equitable under the premises are similarly prayed
for.

Binan City, Laguna for Imus, Cavite, August 25, 2020.

EMILLIE GEMANIL-ESPINA
Counsel for the Petitioners
 PTR 8816538 Binan,Laguna 01.19.2020
IBP LRN 07684, 12.11.2007
MCLE Comp. No. VI-0007548, February 19, 2018,
taken in Baguio City

Attorney’s Roll No. 48117

#184 Camia St. San Jose Village II

Biñan City, Laguna

Copy furnished:

Hon. Rex Sustento

City Prosecutor
rex_sustento@yahoo.com

Hon. Roehl De Castro

City Prosecutor
detroit_625@yahoo.com

The Clerk of Court

Regional Trial Court
Branch 22
Imus, Cavite
RTCImus.Br.22@gmail.com

NOTICE OF HEARING

The Clerk of Court

RTC Branch 22
Imus, Cavite

Please submit the foregoing Motion for the approval of the Honorable
Court immediately upon receipt hereof.

EMILLIE GEMANIL-ESPINA
 EXPLANATION

(Pursuant to Administrative Circular No. 33-2020 of the Supreme Court )

The foregoing motion was electronically sent to the city prosecutors

concered in view of the recent health pandemic.

EMILLIE GEMANIL-ESPINA