REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 212
MANDALUYONG CITY

WILLIAM GO GODINO,
Petitioner,

-versus- SP PROC. No. MC14-9346

JUAN LORENZO DE GUIA

GODINO, ELIZABETH DE GUIA,
and the LOCAL CIVIL
REGISTRAR OF
MANDALUYONG CITY,
Respondents.

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URGENT MOTION FOR CLARIFICATION

[Of The Order]
&
MOTION TO RESOLVE
(Urgent Motion for Postponement & Change of Private Legal
Counsel)

RESPONDENTS, JUAN LORENZO DE GUIA GODINO and

ELIZABETH DE GUIA – GODINO, unto this Honorable Court most respectfully
manifests THAT:

1. An Order dated 26 September 2019 by this Honorable Court was received

by the respondents in the instant case last 23 October 2019, requiring them to file
Comment within ten (10) days to the Motion for Partial Reconsideration filed by the
petitioner;

2. On 4 October 2019, respondents filed their Urgent Motion for Postponement

& Change of Private Legal Counsel which was received by this Honorable Court on
9 October 2019, which until now has yet to be resolved. A copy of the motion is
hereto attached and made integral part hereof as Annex “A”;

3. We, the Respondent stated herein, reiterate that the instant motion was
executed due to the fact that a replacement legal counsel has yet to be seen.
Furthermore, An Order dated 7 October 2019 was received by the Respondents
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which directed the same to secure the services of a new counsel. Likewise, the busy
schedule and unavailability of the respondents made them unable to file the
required pleading on the given period;

4. In the said Motion, respondents in the instant case, prayed for

postponement and / or extension for 60 days of any and all submissions, replies,
COMMENTS, proceedings, actions, hearings and the like with regard and/ or in
relation to this instant case at most. The dispositive portion of the motion is hereto
marked and attached, and made integral part hereof as Annex “A – 1”;

5. Since, we, the Respondents stated herein, filed the said motion, in the
interest of justice, we likewise respectfully moves for clarification as to when to
file the said Comment due to the fact the we prayed for the postponement over
which to file Comment in petitioner’s Motion.

6. In view of the foregoing considerations, it is most respectfully prayed for

that this Honorable Court resolve the Urgent Motion for Postponement & Change of
Private Legal Counsel of the respondents in the instant case.

7. We, the Respondents stated herein, hereby sincerely apologize as well to

this Honorable Court for this Urgent Motion for Clarification [Of The Order] & Motion
to Resolve (Urgent Motion for Postponement & Change of Private Legal Counsel) as it is
not our intention to delay the immediate resolution of this instant case but, such is
solely predicated upon the foregoing reasons and circumstances.

PRAYER

WHEREFORE, in the interest of justice, it is most respectfully prayed of this

Honorable Court that the time of filing of Respondents’ Comment be clarified in
view of the respondents’ Urgent Motion for Postponement & Change of Private Legal
Counsel, and likewise resolve the said motion.

Other just and equitable reliefs are also hereby prayed for.

RESPECTFULLY SUBMITTED this ____ day of _______________ 2019 in

Mandaluyong City, Metro Manila, Philippines.

By :

JUAN LORENZO DE GUIA GODINO ELIZABETH DE GUIA – GODINO

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 NOTICE

THE CLERK OF COURT

Mandaluyong City – Branch 212
Regional Trial Court

Greetings!

Kindly submit the foregoing motion immediately upon receipt hereof for the
consideration and approval of the Honorable Court.

JUAN LORENZO DE GUIA GODINO ELIZABETH DE GUIA – GODINO

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