REPUBLIC OF THE

PHILILPPINES
DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
Province of Negros Oriental

MARIA AGWANTA, NPS Docket NO. INV-13L-00923

Complainant, FOR: Murder

-versus-

JUAN DELA CRUZ,

Respondents.
x ----------------------------------------- x

MOTION FOR RECONSIDERATION

AND EXTENSION OF TIME TO
SUBMIT COUNTER-AFFIDAVIT

Respondent Juan Dela Cruz, assisted by the Public Attorney’s Office

(PAO), unto the Honorable Associate Prosecutor, most respectfully avers, that:

1. Respondent appeared in your office on February 7, 2019 at 1:30pm

without any counter affidavit and was given until February 18, 2019 to submit

the same.

2. Today, however, the accused came to our office to belatedly ask help

with his counter affidavit. Upon perusal from the undersigned counsel, it

appears that his deadline to submit his affidavit have already lapsed.

3. Considering the confusion of the Accused on where to secure his

affidavit, It seemed that he went to the Hall of Justice Dumaguete yesterday,

February 18, 2019 without any counter affidavit and failed as well to meet the

prosecutor as he did not know where and who to approach. Therefore we are

humbly asking the good prosecutor if we may be given additional time to submit
 his counter affidavit

4. There is a need to further study the case and to gather relevant

evidence to support the defense of the Respondents, thus, may we request for

a period of five (5) day extension within which to submit the respondents’

Counter-Affidavit and other supporting documents;

5. That the filing of this motion is done in good faith and not for purposes

of delaying the proceedings of this case but for the reason above-stated.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of the Honorable

Prosecutor that this Motion for Reconsideration to allow accused to submit his

counter affidavit and for an extension of FIVE (5) DAYS within which to submit

Respondent’s Counter-Affidavit and supporting documents, be granted.

February , Bais City, Philippines.

19,2019

PUBLIC ATTORNEY’S OFFICE

Department of Justice
BAIS DISTRICT OFFICE

By:

ATTY. MA. ANA MGDALENA

Public Attorney 1
Roll No. 42993
IBP No. 12345
MCLE Comp. No. VI- 001234

CONFORME:

JUAN DELA CRUZ

(respondent)
 NOTICE

The Clerk
Office Provincial Prosecutor
Province of Negros Oriental

GREETINGS:

Please submit the foregoing motion for the consideration of the Honorable
Provincial Prosecutor immediately upon receipt hereof without further oral argument.

ATTY. MA. ANA MAGDALENA

Copy furnished:

MARIA AGWANTA
Brgy. Cabugan, Bindoy
Negros Oriental