Republic of the Philippines

REGIONAL TRIAL COURT

Second Judicial Region
Branch 03
Tuguegarao City, Cagayan

IN RE: PETITION FOR JUDICIAL

RECONSTITUTION OF TRANSFER
CERTIFICATE OF TITLE NO. T-
38688 ISSUED BY THE REGISTER
OF DEEDS OF TUGUEGARAO
CITY.
Cad. Rec. No. 415
(TCT No. T-38688
Lot No. 374-E-5)

HEIRS OF LUIS DULIN

Namely: GLORIA D.
CARANGUIAN, FELIPA D.
TAGUIBAO, FRANCISCO A. DULIN,
and NICOLASA D. DAMIL, Rep. by
Atty-in-Fact FELIPA D.
TAGUIBAO,
Petitioner/
s.
x--------------------------------x

MOTION TO ENTER APPEARANCE WITH MOTION TO ISSUE

ANOTHER ORDER TO CAUSE PUBLICATION

Petitioners, through undersigned counsel and unto this

Honorable Court most respectfully state:

1. Petitioners recently engaged today the services of counsel to

represent them in the above-captioned case;

2. The above captioned-case is scheduled for hearing on July 7,

2022 at 1:30 o’clock in the afternoon;

3. However, in view of the fact that the petition and annexes

are voluminous, and the fact that his services was recently
engaged by the petitioners, he needs more time to prepare
and to secure relevant documents in support thereof;
 4. As such, he respectfully prays to the Honorable Court to
issue another order for publication to protect the jurisdiction
of the Court;

5. Undersigned also most respectfully enters his appearance as

Counsel for Petitioners and henceforth requests that all
orders and notices be sent in his indicated address.

WHEREFORE, premises considered, it is respectfully prayed

unto this Honorable Court to enter into the records of this case his
appearance, to grant Motion to issue another order and to reset the
scheduled hearing on 7 July 2022 to 17 August 2022.

Respectfully submitted.

Tuguegarao City - 28 June 2022

ATTY. EMIL LOZANO COBALLES

#8A-Arellano Extension, Ugac Sur,
Tuguegarao City, Cagayan
Counsel for the Petitioner
Contacts:0965-723-5107/
coballesemillozano@gmail.com
Roll No. 83586
IBP No. 227065-06-09-22
PTR No. 3113391-06-13-22
MCLE Exempted, pursuant to
MCLE Governing Board Order No. 1,
s. 2008 (New Lawyer)

The Clerk of Court

RTC, Branch 03
Carig, Tuguegarao City

Madam:

Please submit the foregoing Motion for the reconsideration

of the Honorable Court upon receipt hereof. Thank you.

ATTY. EMIL LOZANO COBALLES

Copy furnished:

OFFICE OF THE CITY PROSECUTOR

Tuguegarao City, Cagayan