Urgent Motion To Reset Hearing (mtc 44).docx

Republic of the Philippines METROPOLITAN TRIAL COURT NATIONAL CAPITAL JUDICIAL REGION BRANCH 44, PASAY CITY PEOPLE OF THE PHILIPPINES Complainant, -versus-

Crim. Case No. M-PSY-18-32644-CR For: Violation of Article 172 (1) of the Revised Penal Code (Falsification of Public Documents by a Private Individual and Use of Falsified Document)

JOVITO C. DALUPANG, et al. Accused. x--------------------------------------------------x

URGENT MOTION TO RESET HEARING The Prosecution, through the undersigned, under the direct control and supervision of the Public Prosecutor, unto this Honorable Court, most respectfully state: 1.

The above-entitled case is set for hearing on 19 February 2019 at 8:00 o’clock in the morning.

2.

The supposed to be witness Bank Manager Ferdinand C. Muyargas is unavailable on the said date as he has prior commitments.

3.

In view thereof, the Prosecution is constrained to urgently move for the cancellation of the hearing on 19 February 2019 and for its resetting on the next scheduled hearing date.

PREMISES CONSIDERED, it is most respectfully prayed that the hearing set on 19 February 2019 be cancelled and reset to the next scheduled hearing date. The instant motion is not intended to delay the proceedings but is only due to the aforesaid reason.

for.

Other reliefs just and equitable under the premises are likewise prayed 15 February 2019, Pasay City.

SHERWIN F. GUZON Securities Counsel Human Resource Management Division Human Resource and Administrative Department Roll of Attorneys No. 61089 With my conformity:

Prosecutor Arnel V. Peralta Office of the City Prosecutor Pasay City Notice and Request The Branch Clerk of Court MTC Branch 47, Pasay City ATTY. Counsel for the Accused

Greetings! Please submit to the foregoing Urgent Motion for the consideration and approval of the Honorable Court immediately upon receipt thereof. COPY FURNISHED ATTY. Counsel for the Accused EXPLANATION Copy of the foregoing Urgent Motion is being served upon Counsel for the Accused by registered mail due to manpower constraints. SHERWIN F. GUZON