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Republic of the Philippines

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
PROVINCIAL PROSECUTION OFFICE
Luna, Apayao
VICTORINA R. AGAMATA
Complainant,
- versus OFELIA TACAC & RODOLFO
TACAC,
Respondents.
x--------------------x

II-02-INV-015K-00129
For:
ESTAFA

MOTION FOR RECONSIDERATION

COME NOW respondents SPOUSES RODOLFO TACAC and

OFELIA TACAC, by and through the undersigned counsel, and
files this Motion for Reconsideration to the Order of this
Honorable Office dated December 22, 2015 denying the second
Motion for Extension to file Counter-Affidavit and allege:
1. We acknowledge the policy of this Honorable Office not to
grant second Motion for Extension to file a counteraffidavit;
2. However, the in the interest of substantial justice, we
appeal to this Honorable Office to relax its policy on the
basis of the following:
a) To afford the respondents the opportunity to fully
counter the allegations against them;
b) The undersigned counsel took a long period of time to
examine the allegations in the complaint-affidavit
because there are inter-related cases already filed in
court or prosecutors office as evidence by copies of
the complaint/complaint-affidavits. Copies of the
complaints/complaint-affidavits are hereto attached as
Annexes A, B and C ;
c) The cases when collectively analyzed present a novel
and new perspective to each individual cases;

d) The general objective of the procedure (policy) is to

facilitate the application of justice to the rival claims of
the contending parties, bearing always in mind that
procedure is not to hinder but to promote the
administration of justice;1
e) The joint-counter affidavit was filed in January 5, 2016
before the Order denying the Motion for Extension of
Time to File Counter-affidavit was received;
ACCORDINGLY,
PREMISES
CONSIDERED,
respondents
respectfully move for the reconsideration of the order of this
Honorable Office dated December 22, 2015 denying the second
Motion for Extension to File Counter-affidavit and to beseech this
Honorable Office to admit the Joint Affidavit already filed by
herein respondents.
Aparri, Cagayan for Luna, Apayao. January 8, 2016.

1 Udan vs. Amon, 23 SCRA 837 (1968)