Republic of the Philippines

SUPREME COURT
8th Judicial Region
MUNICIPAL CIRCUIT TRIAL COURT
BRANCH I
Tacloban City

PEOPLE OF THE PHIILIPPINES, CRIMINAL CASE NO. M-

Plaintiff, TAC-

-versus- FOR: VIOLATION OF BP

BLG. 22
CYREEN BINATAC,
Accused.
x---------------------------------------------x

MOTION TO ADMIT JUDICIAL COUNTER-AFFIDAVIT

ACCUSED, through counsel and unto this Honorable Court,

most respectfully states that:

1. On _________, 2019, this Honorable Court issued summons

directing the accused to file a judicial counter-affidavit within ten
(10) days after service thereof, in relation to the case for
violation of B.P. Blg. 22 filed against said accused;

2. However, for the reason that accused had no legal knowledge

nor understanding on the rules of procedure, said summons
was not served upon him and therefore was not able to file his
answer to the petition;

3. It was only on November 6, 2019, after arriving from Manila,

that respondent was able to get hold of a copy of the summons
and the petition such that the filing of this comment/opposition
is within the reglementary period of five (5) days provided for;

PRAYER

WHEREFORE, it is most respectfully prayed of this Honorable

Court, that this Motion to Admit be granted and the respondent’s
Comment / Opposition be admitted.

Other reliefs that are just and equitable under the premises are
likewise prayed for.

RESPECTFULLY SUBMITTED.
 November 11, 2019, Tacloban City.

MA. CHRISTINA ERNEST U. MOLINA

Counsel for the Respondent
0977 R. Mendiola St., Brgy. Sta Cruz,
Palo, Leyte, Philippines 6501
Contact No. 09173217334
Roll of Attorneys No. 72489/06-14-19
IBP No. 089047/06-10-19, Leyte Chapter
PTR No. PL 7904947/07-24-19, Tacloban City
MCLE Compliance – On process August 2019

NOTICE OF HEARING

ATTY. REGINA P. ELIZARDE

Clerk of Court
RTC Branch 7 (Family Court)
Magsaysay Blvd., Tacloban City

COPY FURNISHED: By personal service

ATTY. CHRISTINE MARY ROSE K. SAJONIA

Counsel for the Petitioner
PUBLIC ATTORNEYS OFFICE
Tacloban City

GREETINGS:

Please be informed that the undersigned shall submit the

foregoing Comment/Opposition to the Honorable Court for its
consideration and approval.

MA. CHRISTINA ERNEST U. MOLINA