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Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES


10th Judicial Region
Branch 2
Cagayan de Oro City

PEOPLE OF THE PHILIPPINES, CRIM CASE NOS.


M15-10-1780
Plaintiff, to M15-10-1781

FOR: QUALIFIED TRESPASS


-versus- TO DWELLING AND
GRAVE COERCION

MERLYN T. MINDORO, ET. AL.,


Accused.

x -----------------------------------------------/

M OT I ON F O R R E C O NSI D E RA T I O N

COMES NOW Private Complainant, by counsel, and unto this


Honorable Court most respectfully moves for reconsideration of its
Order dated September 20, 2016 and in amplification thereof
complainant most respectfully avers:

1. That this Honorable Court in its Order dated September 20,


2016, dismissed the above entitled case against Merlyn T.
Mindoro on the ground for lack of interest on the part of
the private complainant;

2. That Private Complainant was not able to appear in court


for three (3) consecutive hearing dates set for the very
reason that he and his legal counsel did not receive any
copy of the Notice of Hearing because it was mistakenly
sent to the PNP Chief of Police of Quezon City;

3. That the Private Complainant still has very much interest


in pursuing this criminal case against the Accused and in
fact, if the notices were actually received by him, he would
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have not missed any of the hearing dates set by this


Honorable Court.

WHEREFORE, premises considered, it is most respectfully prayed


of this Honorable Court that the Order dated on 26th September 2016
be set aside and this case be set for trial.

OTHER RELIEFS just and equitable are likewise prayed for.


January 27, 2017, Cagayan de Oro City

ATTY. ALEJANDRO JOSE C. PALLUGNA


Counsel for Complainant
PALLUGNA PALLUGNA QUIMPO & ALENTON LAW OFFICES
Borromeo Building, Tomas Saco 14th Sts.,
Macasandig, Cagayan de Oro City
Attorneys Roll No. 37984
IBP No. 1059570 (Jan. 9, 2017) CDO
PTR. No. 3347835 (Jan. 9, 2017) CDO
MCLE Compliance No. V 0009612 (valid until 04/14/2019)
Tel. No. (088) 857 1864

WITH CONFORMITY:

ACP Rhandy G. Ilisan


Office of the City Prosecutor
Tourism Hall
Cagayan de Oro City

NOTICE OF HEARING:
(with copy furnished)

Atty. Archibald Lagamon


CDT - KAI Building
Hayes Ext., Pinikitan
Cagayan de Oro City
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Atty. Evangeline T. Carrasco


119 Pabayo Cruz, Taal St.
Cagayan de Oro City

Office of the City Prosecutor


Tourism Hall
Cagayan de Oro City

Office of the Solicitor General


136 Amorsolo St. Legaspi Village
Makati City

Greetings!

Please take notice that the undersigned counsel will submit the
foregoing Motion for the consideration and approval of this
Honorable Court, sans appearance of counsel. Thank You.

ATTY. ALEJANDRO JOSE C. PALLUGNA

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