REPUBLIC OF THE PHILIPPINES

SEVENTH JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 12, CEBU CITY

HEIRS OF THE LATE

Civil Case No. RTC-125106
KARA BAGUNAS,
Plaintiffs,
For: JUDICIAL PARTITION
-versus-

HEIRS OF THE LATE

MARLA ANGELIE SO,
Defendants.
x-----------------------------------x

MOTION FOR SUBSTITUTION

OF COUNSEL OF RECORD

COMES NOW, the plaintiffs, through the undersigned counsel, unto this
Honorable Court most respectfully states that:

1. Plaintiff CARLOS VILLARIN who is one of the heirs of the late

KARA BAGUNAS died last January 09, 2020. Attached herewith is a
copy of his Certificate of Death;

2. The counsel of record for the plaintiffs is ATTY. EUNICE MAYE

RUIZ;

3. The aforementioned plaintiffs have respectfully engaged the services of

the undersigned counsel to be their new counsel of record;

4. That both the plaintiffs and the undersigned counsel have given their
consent to the substitution.

PRAYER

WHEREFORE, it is respectfully prayed that prayed that all summonses,

orders and processes of the court be sent and addressed to ATTY.
HOREB FELIX B. VILLA with office address at 86-B. A. Mabini St.,
Cebu City and that he be declared as the new counsel of record for the
plaintiffs HEIRS OF THE LATE KARA BAGUNAS.

Other reliefs and remedies just and equitable are likewise prayed for.

Respectfully submitted.

Cebu City, March 27, 2020.

By:

ATTY. HOREB FELIX VILLA

Counsel for Plaintiffs
86-B. A. Mabini St., Brgy. San Roque, Cebu City
Roll of Attorneys No. 165876
IBP No. 165762, 01/08/2020, Cebu City
PTR No. 154643, 01/10/2020, Cebu City
MCLE Compliance No. VI-0000112253- 06/30/2019
Email Address: villa.horebfelix@gmail.com
Contact No.: 0917-633-8899

NOTICE OF HEARING:

To : Atty. Lei Christinanne De los Angeles

Clerk of Court
RTC-Branch 12, Cebu City

Greetings!

Please set hearing of the foregoing motion for resolution on Friday, April
3, 2020 at 9 o’ clock in the morning or at a date and time convenient to
the Honorable Court.

Sincerely,

ATTY. HOREB FELIX B. VILLA

Counsel for Plaintiff

VERIFICATION
REPUBLIC OF THE PHILIPPINES )
CITY OF CEBU ) S. S.

We, JINNELYN O. LI, of legal age, Filipino citizen, married, and

resident of 25-B Beverly Hills Subdivision, Lahug, Cebu City 6000, and
JOHN MICHAEL LEQUIGAN, of legal age, married, and a resident of
123-A Junquera St., Cebu City 6000, in our capacity as the heirs of the
late Kara Bagunas, after having been duly sworn to in accordance with
law do hereby depose and say:

1. That we are the plaintiffs in the above- entitled case;

2. That we have caused the preparation of the foregoing Motion for

Substitution of Counsel of Record and have read the allegations contained
therein;

3. The allegations in the said complaint are true and correct of our own
knowledge and authentic records.

IN WITNESS WHEREOF, we have hereunto affixed our signatures this

27th of March, 2020, in the City of Cebu, Philippines.

JINNELYN O. LI JOHN MICHAEL LEQUIGAN

Affiant Affiant

SUBSCRIBED AND SWORN to before me this 27th day of March

2020, in the City of Cebu, affiants exhibiting to me their respective
Drivers Licenses with No.: 12345 issued at LTO, Cebu City on December
16, 2019, and with License No. 54321 issued at LTO, Cebu City on April
1, 2018.

ATTY. LOU DELIANNE REBOJA

Notary Public for Cebu City
EH 403, USC Law Building,
Pelaez St.,Cebu City
Commission No. 12-51
Until December 31, 2021
Roll of Attorneys No.: 12345
IBP No.: 125745,01/05/2020, Cebu City
PTR No.: 432876, 02/01/2020, Cebu City
Doc. No.: ___;
Page No.: ___;
Book No.:___;
Series of 2020.

Copy furnished by personal service:

ATTY. ELMAR TAGALOGUIN

Counsel of the Defendant
23 MCIAA Building, Lapu-Lapu City

PROOF OF SERVICE

I, RUBIEROSSE DONGALLO, messenger for ATTY. HOREB

FELIX VILLA, hereby certify that I personally delivered plaintiffs
counsel’s MOTION FOR SUBSTITUTION OF COUNSEL OF
RECORD dated March 27, 2020 to ATTY. ELMAR TAGALOGUIN
with address at 23 MCIAA Building, Lapu-Lapu City, Philippines.
The Motion was received by the counsel for the defendant himself.

IN WITNESS WHEREOF, I have hereunto set my hand this 27 th day of

March, 2020 in Cebu City, Philippines.

RUBIEROSSE DONGALLO
Affiant

SUBSCRIBED AND SWORN to before me this 27th day of March

2020, in the City of Cebu, affiant exhibiting to me her Drivers License
with No.: 23465 issued at LTO, Cebu City on December 2, 2019. and

ATTY. LOU DELIANNE REBOJA

Notary Public for Cebu City
EH 403, USC Law Building,
Pelaez St.,Cebu City
Commission No. 12-51
Until December 31, 2021
Roll of Attorneys No.: 12345
IBP No.: 125745,01/05/2020, Cebu City
PTR No.: 432876, 02/01/2020, Cebu City

Doc. No.: ___;

Page No.: ___;
Book No.:___;
Series of 2020.