REPUBLIC OF THE PHILIPPINES

Court of Appeals
Cebu City

JANN DANAE AOALIN ANINAG DE ASIS,

Petitioner,

-versus- CIVIL CASE: 12345

For: Reconveyance

LOIS NISNISAN DYBONGCO,

Respondent.

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URGENT MOTION FOR EARLY RESOULTION

COMES NOW, the respondent, by counsel, unto this Honourable

Court, most respectfully avers that:

1. On November 24, 2006, the Trial Court rendered a Decision

cancelling OCT No. OP-37324 and in lieu thereof, ordering the issuance of a
new TCT in the name of Lois Nisnisan Dybongco;

2. On March 12, 2015, the case was elevated to this Court who
affirmed the November 24, 2006 Decision;

3. On March 17, 2015, the Petitioner filed a Motion for

Reconsideration of the above-mentioned decision;

4. In accordance with Rule 52 of the Rules of Court, a motion for

reconsideration shall be resolved within 90 days from the date when the it is
submitted for resolution;

5. It has been more than four years but no action or resolution has
been done by this Court;

6. The resolution of the above mentioned motion has become

exigent so as not to frustrate the ends of justice; and

7. This motion is intended solely for the purpose alluded thereto.

 PRAYER

WHEREFORE, it is most respectfully prayed of this Honourable

Court that this motion be resolved in the soonest possible time.

Other just and equitable reliefs are likewise prayed for.

Quezon City for Cebu City, September 13, 2019.

ATTY. ANGELICA ERNESTINE L. BAROÑA

Counsel for Respondent
1 Mindanao Ave. Quezon City
Attorney’s Roll: 12345
IBP No. 123456; January 1, 2019; Quezon City
PTR No. 123456; January 1, 2019; Quezon City
MCLE Compliance No. 12345; January 1, 2019; Quezon City

NOTICE OF HEARING

Clerk of Court
Court of Appeals
Cebu City

Greetings!

Due to the non-litigious character of the foregoing, kindly submit this

Manifestation for consideration of this Honourable Court immediately upon
receipt thereof.

Atty. Angelica Ernestine Barona

Explanation of Service: Due to lack of manpower, a copy of this Motion

for Early Resolution shall be served by registered mail.

Copy furnished:

Atty. Juan dela Cruz

Counsel for Petitioner
12 Tower 3, 45 Blvd., Cebu City
Republic of the Philippines)
Manila City ) S.S.
x------------------------------------x

AFFIDAVIT OF SERVICE

I, MES SENGER, of legal age, Filipino, single and a resident of 1

ABC St. Def Village, Manila, declare under oath that:

1. I am employed as a messenger of Atty. Angelica Ernestine

Barona with address at 1 Mindanao Ave. Quezon City; and

2. In my aforementioned capacity, I had served a copy of this

Motion for Early Resolution by registered mail by depositing a copy in the
post office in a sealed envelope, addressed to the Petitioner’s lawyer at his
office in 12 Tower 3, 45 Blvd., Cebu City.

Manila City, September 14, 2019.

(sgd) Mes Senger

Affiant

SIGNED AND SWORN before me this September 14, 2019 at

Manila by the affiant whom I personally know.

(sgd) John Doe

Notary Public
123 ABC Tower, Manila
Commission Series 12345
Until December 31, 2019
Roll of Attorney: 12345
PTR 12345; January 1, 2019; Manila
IBP 12345; January 1, 2019; Manila

Doc 1;
Page 1;
Book I;
Series of 2019.