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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


REGIONAL TRIAL COURT
CITY OF MAKATI
BRANCH 56
IN THE MATTER OF THE
PETITION FOR DECLARATORY
RELIEF
REGARDING
THE
PROPER
IMPLEMENTATION,
APPLICATION,
EFFECTIVITY,
AND
AVAILMENT
OF
PRIVILEGES GRANTED AND
PROVIDED UNDER REPUBLIC
ACT 7432 (AN ACT TO
MAXIMIZE
THE
CONTRIBUTION OF SENIOR
CITIZENS
TO
NATION
BUILDING, GRANT BENEFITS
AND SPECIAL PRIVILEGES
AND FOR OTHER PURPOSES),
AS AMENDED BY REPUBLIC
ACTS NO. 9257 (EXPANDED
SENIOR CITIZENS ACT OF
2003) AND 9994 (EXPANDED
SENIOR CITIZENS ACT OF
2010),
EDGAR U. ILARDE, RODRIGO
C. DOMINGO, JR., and LUIS T.
ARRIOLA, suing in their
individual capacity and in
behalf of the class of all
senior
citizens
residing
permanently or temporarily
in the Philippines,
Petitioners,
SPECIAL CIVIL CASE NO. 15267

-versusDEPARTMENT
OF
HEALTH
(DOH),
DEPARTMENT
OF
TRADE AND INDUSTRY (DTI),
ET AL.,
Respondents.
x-------------------------------------------x

ENTRY OF APPEARANCE
1

WITH MOTION FOR EXTENSION OF TIME


TO FILE POSITION PAPER
RESPONDENT
R
&
E
TRANSPORT,
INC.,
(RESPONDENT R & E) by the undersigned counsel, most
respectfully states THAT:
ENTRY OF APPEARANCE
1.

Respondent R & E had just engaged the legal services of the


Law Firm to represent it as its counsel in this case.

2.

Thus, the Law Firm most respectfully enters its appearance


as counsel for respondent R & E.

3.

It is therefore respectfully requested that all notices, orders,


pleadings and other processes be furnished the undersigned
Law Firm located at the address written below.
MOTION FOR EXTENSION OF TIME
TO FILE POSITION PAPER

4.

During the last hearing of this case, the Honorable Court


required the parties to file their respective Position Papers.

5.

The undersigned counsel needs ample time to study the


records of the case considering that it is its first time to
peruse the same.

6.

It is for this reason that the undersigned begs the utmost


indulgence of this Honorable Court to give additional fifteen
(15) days within which to comply with the order of the
Honorable Court to submit its Position Paper.

PRAYER
WHEREFORE, in light of the foregoing premises,
respondent R & E most respectfully prays of this Honorable
Court to NOTE this Entry of Appearance and GRANT its
Motion for Extension of Time to File Position Paper giving
respondent R & E additional 15 days from today, or until
March 15, 2016, within which to submit its Position Paper.
Other reliefs just and equitable under the foregoing
premises are likewise prayed for.
2

Quezon City for the City of Makati, February 29, 2016.


THE LAW FIRM OF

CASAUAY COLOMA FRANCISCO ESTRELLADO


& ASSOCIATES
Counsel for Respondent R & E Transport, Inc.
Suite 300-C Delta Bldg. West Avenue
Corner Quezon Avenue, Quezon City
BY:

RICHARD LAGGUI SUYU


IBP OR # 1025281, 01/13/2016 Cagayan Chapter
PTR #5007677, 01/19/2016, City of Manila
Roll of Attorney. 64459
MCLE Compliance No. (Exempted pursuant to
MCLE Governing Board Order No. 1, s. 2008)
Mobile No. 09151928776
Copy Furnished:
ATTY. NELSON A. LOYOLA
Counsel for Petitioners
NELSON A. LOYOLA AND ASSOCIATES
Suite 201 Carreon Building
2746 Zenaida Street, Barangay Poblacion
Makati City
EXPLANATION ON SERVICE BY REGISTERED MAIL
(Pursuant to Section 11, Rule 13 of the Rules of Court)
Due to distance, heavy traffic and time constraint, as well
as inadequate messenger personnel, copies of this Entry of
Appearance with Motion for Extension of Time to File Position
Paper was served by private courier to the Court and to
petitioners counsel.
RICHARD LAGGUI SUYU