REPUBLIC OF THE PHILIPPINES

THIRD JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 83
MALOLOS BULACAN

IN RE: PETITION FOR

CORRECTION OF ENTRY IN THE
TRANSFER OF CERTIFICATE OF
TITLE NO. T-560108 (M)

FREEDOM TO BUILD, INC.

Petitioner,

- versus - Case No. P-452-2021

THE REGISTRY OF DEEDS OF
MEYCAUAYAN, BULACAN
Respondent.
x-------------------------------------------------x

URGENT MOTION TO RESET HEARING

PETITIONER, through undersigned counsel unto to this

Honorable Court, respectfully alleges:

1. During the last scheduled hearing, the Honorable Court

has set the continuation of the presentation of Petitioner’s
jurisdictional requirements on 12 September 2022.

2. On 11 September 2022, undersigned counsel received

information that he was listed as a close contact of a
person who has recently tested positive for Covid 19.

3. On this score, undersigned counsel, in line with the

existing health and safety protocols for Covid 19 and in
consideration of the health and safety of the Honorable
Court and the public is left with no choice but to self-
isolate until he can take the necessary antigen/RT-PCR
Test to determine if he contracted the Covid 19 virus.

4. Considering the foregoing and in the interest of the

health and safety of the Honorable Court, staff and
litigants, undersigned counsel respectfully requests that
 the hearing set on 12 September 2022 be cancelled and
reset on a later date.

PRAYER

WHEREFORE, it is respectfully prayed that the Urgent Motion

to Reset Hearing be granted and that the hearing set on 12
September 2022 be CANCELLED and RESET on another day as may
be preferred by the Honorable Court.

Other just and equitable relief and remedies are likewise prayed
for.

Muntinlupa City for Malolos, Bulacan, 11 September 2022.

E.P. MARTINEZ MARTINEZ LAW OFFICES

Counsel for the Petitioner
Suites 1405 and 1406 Richville Corporate Tower
1107 Alabang-Zapote Road, Madrigal Business Park
Ayala-Alabang, Muntinlupa City
(632)8807-9393/(632)8807-5353

By:

JAIME MIGUEL S. SANTOS III

Roll of Attorneys No. 73576
PTR No. 3974021/01.04.2021/Muntinlupa
IBP No. 141028/01.04.2021/PPLM
Exempted, pursuant to MCLE Governing Board Order No. 1, s. 2008 1
Email address: jaimesantos817@gmail.com
Contact Number: 0917-7761989

NOTICE OF HEARING

THE CLERK OF COURT

Branch 83
Malolos City

OFFICE OF THE SOLICITOR GENERAL

134 Amorsolo St. Legaspi Village
Makati City

1
Atty. Jaime Miguel S. Santos III was admitted to the Philippine Bar on 19 June 2019
OFFICE OF THE PROVINCIAL PROSECUTOR
Office of the Provincial Prosecutor
Malolos Bulacan

REGISTRY OF DEEDS OF BULACAN

(MEYCAUAYAN BRANCH)
Muralla St., Brgy. Iba,
Meycauayan, Bulacan

G R E E T I N G S:

In view of its non-litigious nature, kindly be informed that the

undersigned counsel will submit the foregoing motion for this
Honorable Court’s consideration immediately upon receipt thereof.

ATTY. JAIME MIGUEL S. SANTOS III

EXPLANATION

Due to physical and logistical constraints due to the current

circumstance of the undersigned counsel, the foregoing Motion to
Reset Hearing was filed via electronic mail.

ATTY. JAIME MIGUEL S. SANTOS III

Copy Furnished: (by electronic mail)

OFFICE OF THE SOLICITOR GENERAL

134 Amorsolo St. Legaspi Village
Makati City
efile@osg.ph

OFFICE OF THE PROVINCIAL PROSECUTOR

Office of the City Prosecutor
Malolos Bulacan
opp.bulacan@gmail.com

REGISTRY OF DEEDS OF BULACAN

(MEYCAUAYAN BRANCH)
Muralla St., Brgy. Iba,
Meycauayan, Bulacan
ja.hidalgo@lra.gov.ph