REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SECOND JUDICIAL DISTRICT
TUGUEGARAO CITY, CAGAYAN
BRANCH 2
Email Address: rtc1tug002@judiciary.gov.ph

PEOPLE OF THE PHILIPPINES,

Plaintiff,

Crim. Case No. 21515

-versus- Crim. Case No. 21516-22
For: Qualified Theft

QUINTIN J. PAGULAYAN, JR.,

Accused.
x---------------------------------------------x

URGENT MOTION FOR

POSTPONEMENT

NOW COMES the undersigned counsel for the accused Quintin J.

Pagulayan, Jr., and to this Honorable Court, most respectfully states that:

1. The hearing of this case has been set today, October 20, 2023 at 2:00
o’clock in the afternoon.

2. However, the undersigned counsel regretfully informs the Honorable

Court that he cannot attend said hearing, the reason being that the
undersigned counsel just contracted cough, colds and flu, with
accompanying headache, thereby rendering him unfit to travel and
attend the hearing today. A copy of his medical prescription is hereto
attached as Annex “1” and made an integral part hereof. The
undersigned counsel undertakes to submit a duly notarized medical
certificate should the Honorable Court deem it necessary.

3. With this, the undersigned is constrained to respectfully request the

Honorable Court to reset the hearing of the instant case to another date
subject to the availability of the Honorable Court’s calendar.

4. That this motion is made in good faith and not intended to delay the
proceedings of the instant case.

5. The undersigned counsel and the accused herein hereby apologize to

this Honorable Court and the prosecution for this short notice.

PRAYER

WHEREFORE, based on the premises presented, it is most respectfully

prayed that the hearing of the instant case on October 20, 2023 at 2:00 o’clock in
the afternoon be reset to another date subject to the availability of the Honorable
Court’s calendar.

This is hereby respectfully submitted today, 20 th day of October 2023, in

Antipolo City, for Tuguegarao City.

ATTY. NESTOR P. PINLAC

Counsel for the Accused
3/F, No. 42 GSIS Ave., Cogeo Village
Brgy. Bagong Nayon I, Antipolo City
IBP No. 181791 (2023)/4 Jan. 2022/Pang.
PTR No. 5102681/3 Jan. 2023/ Mandaluyong City
MCLE Compliance No. VI- finished 18 November2022
Roll of Attorneys No. 51293
MCLE Compliance No. VII – on-going#0917-8760521
hoodzie_87345@yahoo.com.ph

COPY FURNISHED:

Office of the City Prosecutor

Tuguegarao City, Cagayan
(ocptuguegarao@doj.gov.ph)

ATTY. MILA CATABAY-LAUIGAN

Private Prosecutor
13 Blumentritt St., Centro 4
Tuguegarao City, Cagayan
(milalauiganlaw@gmail.com)