REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIOAL TRIAL COURT
BRANCH 212
MANDALUYONG CITY

IN RE: PETITION FOR

CANCELLATION OF ENTRY IN
THE CERTIFICATE OF LIVE
BIRTH OF JUAN LORENZO DE
GUIA GODINO,

WILLIAM GO GODINO,
Petitioner,

SP PROC. No. MC14-9346

-versus-

JUAN LORENZO DE GUIA

GODINO, ELIZABETH DE
GUIA, and the LOCAL CIVIL
REGISTRAR OF
MANDALUYONG CITY,
Respondent.
x-------------------------------------------x

URGENT MOTION FOR POSTPONEMENT

RESPONDENT, the undersigned and to this Honorable Court

most respectfully manifests:

1. That the Court issued an Order setting for the initial

presentation of Respondent’s evidence on September 26, 2019 at
2:00 o’clock in the afternoon. (Copy of the Order duly received by the
undersigned is hereto attached and marked as Annex “A”);

2. That respondent loss trust and confidence to their previous

counsel Atty. Jose Ventura Aspiras of Carpio & Bello Law Offices;

3. That by reason of which respondent terminated their legal

relationship with their counsel and to the firm. Atty. Aspiras formally
submits his Withdrawal of Appearance dated September 20, 2019 as
counsel for the respondent. (Copy of the Withdrawal of Appearance
dated September 20, 2019 is hereto attached and marked as Annex
“B”);

4. Unfortunately the respondent, as of the moment has yet to

find a counsel to represent them with the case, hence, no one will
attend to the hearing of the above-captioned case. Thus battle was
left to respondent to fight on their own.

5. That respondent apologizes to the Honorable Court for the

resetting of the case and it is not their intention to delay their
immediate resolution but solely predicated upon the foregoing
reason.

WHEREFORE, premises considered, it is respectfully prayed of

the Honorable Court that the hearing for the initial presentation of
Respondent’s evidence on the above-entitled case on September 26,
2019 at 2:00 o’clock in the afternoon be cancelled and the same be
reset to another day preferably on the last week of November 2019 or
at the convenience of this Honorable Court.

Pasig City, Philippines, September 26, 2019.

By:

JUAN LORENZO DE GUIA GODINO

175 MERCED ST. PACO, MANILA

ELIZABETH DE GUIA GODINO

175 MERCED ST. PACO, MANILA

Copy furnished:

Atty. Maricris B. Pahate

Andres Padernal & Paras Law Offices
Counsel for Petitioner
8th Floor, Saguittarius Office Condominium
No. 111 HV dela Costa Street
Bel Air, Salcedo Village, Makati City
Office of the City Prosecutor
Mandaluyong City

Office of the Solicitor General

134 Amorsolo St., Legaspi Village Makati City

The City Local Civil Registrar

Mandaluyong City