Republic of the Philippines

OFFICE OF THE OMBUDSMAN

Agham Road, Diliman, Quezon City 1101

JUAN PEDRO C. DELA CRUZ and

JOHN PETER C. DELA CRUZ, JR.
Complainants,

- versus – OMB-C-A-12-3456
For: Grave Misconduct; Gross
Neglect of Duty; Conduct
Prejudicial to the Best Interest
of the Service; Oppression

MARIA B. BATUMBAKAL
Secretary

JUANITA C. DEOGRACIAS
Undersecretary

All of: Department of Blahblahblah

Respondents.

x------------------------------------- x

JOINT MOTION FOR EXTENSION OF TIME

TO FILE COUNTER-AFFIDAVIT

Respondents MARIA B. BATUMBAKAL, and JUANITA C.

DEOGRACIAS, unto the Honorable Office of the Ombudsman, most
respectfully states:

1. The herein respondents received on June 10, 2020 the

Order to file our Counter-Affidavit to the above-captioned complaint,
within a non-extendible period of ten days from receipt thereof;

2. Because the complaint pertains to the same alleged

action/s, in turn alleged to have been participated in by the
respondents in a chain of events, the respondents have agreed to file
their Counter-Affidavit jointly to facilitate an integrated presentation
of facts and for efficiency in the records of the matter;

3. However, respondents, both senior officials of the

Department of Blahblahblah, will be unable to meet the period set by

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this Honorable office for the filing of a joint Counter-Affidavit, for the
following reasons:

a. The respondents will need more time to retrieve the

pertinent records on the subject matter of the complaint, in
order to present a complete narration of facts with
corresponding evidence;

b. Respondent Batumbakal, as Department Secretary, is

constantly attending to equally urgent responsibilities, and
thus will need more time to attend to the preparation of the
Counter-Affidavit;

c. Respondent Deogracias is presently on official travel from

June 9 to 18, 2020 in Orlando, Florida as part of the
Philippine Delegation to the World Blahblahblah
Organization Annual Convention;

4. The earliest time that the respondents can meet, with

both personally present, to examine the documents and prepare their
joint Counter-Affidavit is on June 20, 2020, which is already the end
of the period stated in the Order;

5. In view of the foregoing unavoidable circumstances, the

respondents are constrained to respectfully request for an additional
period of fifteen (15) days, or up to July 5, 2020, to submit their joint
Counter-Affidavit;

6. This request is not intended to delay the proceedings, but

solely due to the afore-cited reasons and the need to come up with a
judicious joint Counter-Affidavit.

7. Respondents, as public servants reposed with the trust

and duties of their public office, also take the opportunity of this
Motion to unequivocally assure this Honorable Office and the
complainants that absolutely no “undue influence or pressure on any
witnesses against him/her, or tampering with evidence that may be
used against him/her”, as expressed in the complaint, shall be
exerted or resorted to by any and all of the respondents.

PRAYER

WHEREFORE, respondents most respectfully prays that this

Honorable Office grants the respondents an additional period of
fifteen (15) days, or up to July 5, 2020, to file their joint Counter-
Affidavit and controverting evidence.

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 Other relief just and equitable are likewise prayed for.

June 18, 2020; Quezon City, Philippines.

MARIA B. BATUMBAKAL

JUANITA C. DEOGRACIAS

Copy furnished:

JUAN PEDRO C. DELA CRUZ and

JOHN PETER C. DELA CRUZ, JR.
123 Times St., cor, West Ave.
Quezon City