Republic of the Philippines

REGIONAL TRIAL COURT

10th Judicial Region
Branch 38
Cagayan de Oro City

TEODULO ACDAL, CIVIL CASE NO. CV-ORD-2016-256

Plaintiff,
FOR: ANNULMENT OF TITLE &
- versus - RECONVEYANCE

SPOUSES JUISIN & BEATRIZ ACDAL,

Defendants.
X----------------------------------------/

URGENT MOTION TO RESET HEARING

DEFENDANTS SPOUSES JUISIN and BEATRIZ ACDAL, through undersigned counsel for
the purpose of this motion, unto this Honorable Court, most respectfully files this Motion
and further avers that:

1) The above-captioned case is scheduled for hearing on 6 August 2019 at 8:30 in the
morning and another scheduled hearing on 20 August 2019 at 8:30 in the morning
before this Honorable Court.

2) Atty. CANCIO NICANOR M. GUIBONE has decided to withdraw his appearance as

counsel for the above- captioned case due to professional and personal reasons
particularly his upcoming legal engagement with a private company in Manila in
which he is scheduled to leave for training this 5 August 2019 until 23 August 2019.

3) Defendants through undersigned Counsel, for the purpose of this motion only, thus
begs the indulgence and understanding of this Honorable Court and is constrained
to plea for the resetting of two (2) scheduled hearings and humbly requests this
Honorable Court that defendants be given an ample time to look for another
counsel that may subsequently continue to defend their rights in the interest of
justice and equity.

4) This Motion is filed in good faith and with honest intentions and is not intended to
delay the proceedings of this case nor to defy, negate or violate any order or
resolution of this Honorable Court including the resetting of hearing schedule, but
for the reason above-stated, in the interest of justice and equity.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed unto this Honorable

Court that the hearing scheduled on 6 August 2019 at 8:30 in the morning and 20 August
2019 at 8:30 in the morning be postponed and rescheduled at a date convenient and
available to the calendar of this Honorable Court in the interest of justice and equity.
 Other relief and remedies just and equitable under the premises are likewise prayed for.

Most respectfully submitted.

2 August 2019. Cagayan de Oro City, Philippines.

GUIBONE & GUIBONE LAW OFFICE

Counsel for Respondents
Corner 2nd-3rd Sts., Nazareth, Cagayan de Oro City
By:

ATTY. CANCIO P. GUIBONE

MCLE Compliance No. IV-0022604, 11-28-13
MCLE Compliance No. V-0001138, 11-28-13
MCLE Compliance No. VI-0003844, 11-3-2017
PTR No. 9520180, 1-3-19, Mis. Or.
IBP No. 062648, 1-4-19
Attorney’s Roll No. 34300
Mobile No. 0935-677-8896
TIN No. 139-953-278
Cagayan de Oro City

NOTICE
CLERK OF COURT
RTC Branch 38, Cagayan de Oro City

ATTY. ENRIQUE NADUMA

Counsel for Plaintiff
Naduma Law Office, Door #6, Petron Gas Station, Vamenta Boulevard
Ilaya, Carmen, Cagayan de Oro Ciy

GREETINGS:

Please submit the foregoing Motion unto the Honorable Court immediately upon
receipt hereof or on August 6, 2019 at 8:30 in the morning for his kind resolution and
approval, sans appearance.

ATTY. CANCIO P. GUIBONE

Copy furnished:

ATTY. ENRIQUE NADUMA

Naduma Law Office
Door #6, Petron Gas Station, Vamenta Boulevard
Ilaya, Carmen, Cagayan de Oro Ciy