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REPUBLIC OF THE PHILIPPINES


REGIONAL TRIAL COURT
7th Judicial Region
Branch 66 Talisay City, Cebu

IN RE: PETITION FOR THE ISSUANCE


OF OWNER’S DUPLICATE OF ORIGINAL
CERTIFICATE OF TITLE NO. T-43403
IN LIEU OF THE ONE THAT WAS LOST.

RET. GEN. LISANDRO ABADIA,


Petitioner,

-versus- LRC CASE NO. TCL 2016-31

REGISTER OF DEEDS OF
PROVINCE OF CEBU
Respondent.
x----------------------------------------------x

MOTION FOR RECONSIDERATION WITH MOTION TO ADMIT


FORMAL OFFEER OF EVIDENCE

COMES NOW, the petitioner through undersigned counsel, unto this


Honorable Court most respectfully states:

1. That an order was issued dismissing this case without prejudice;

2. That petitioner moves to reconsider the order of dismissal in the interest


of justice;

3. That the delay of the petitioner in moving this case was due to lack of
communication considering that petitioner is living in the United States of
America;

4. That petitioner had already presented his witness within his authority and
had already identified documents relevant to this petition;

5. That the petitioner is no longer presenting additional witness and hereby


respectfully file the attached formal offer of evidence;

6. That the undersigned counsel humbly apologizes to this Honorable Court


for the delay of this case and humbly ask for its kind consideration;
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PRAYER

WHEREFORE, premises considered, petitioner moves that an Order be


issued reinstating this case and admit the formal offer of the petitioner and to
submit this case for decision of this Honorable Court.

Respectfully Submitted. Cebu City, Philippines, December 20, 2018.

DAVIDE & SUSUSCO LAW OFFICE


COUNSEL FOR THE PETITIONER
RM. 306, Diaz Bldg., J. Avila St., Osmena Blvd.
Capitol Site, Cebu City, Philippines
Tel. No. (032) 4199720
By:

ATTY. GIOVANNI D. SUSUSCO


IBP Cebu City No. 023763 on 1-03-2018
PTR No. 3018163/ 2-07-2018/ Cebu Province
Roll of Attorneys No. 53097
Admitted to the Bar on April 26, 2007
MCLE COMPLIANCE NO. V-0008256

THE HON. CLERK OF COURT


REGIONAL TRIAL COURT
Branch 66, Talisay City, Cebu

GREETINGS!

Kindly submit and take notice of the foregoing for the kind consideration of
the Honorable Court.

Atty. Giovanni Sususco

Copy Furnished:

Office of the Talisay City Prosecutor


Palace of Justice, Talisay City, Cebu

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