Republic of the Philippines

Department of Environment and Natural Resources

Office of the Provincial Environment and Natural Resources
Capitol Drive, Malaybalay City
RHODA K. BALATAYO-VALMORIA,
In her individual capacity and as
Representative of the HEIRS OF THE
LATE
SPOUSES
MAGDALENO
BALATAYO,
SR.
AND
EMILIANA
KINDOM-BALATAYO,
Protestants,

PENRO CLAIM NO. ____________

For: PROTEST TO THE APPLICATION
FOR TITLE OF LOT NO. 41061-54,
CSD-10-19200, IDENTICAL TO LOT
NO. 42008, CAD 864 LOCATED IN
KALASUNGAY, MALAYBALAY CITY,
BUKIDNON.

-versusROSALINDA L. HERNANDEZ,
Applicant.
X-------------------------------------------------------------------------------------X
MOTION FOR POSTPONEMENT WITH MANIFESTATION
COMES NOW, the undersigned counsel for the Protestants, unto this
Honorable Office of the Department of Environment and Natural Resources (DENR),
most respectfully manifests:
1. That, the undersigned counsel was verbally informed today of the
hearing scheduled tomorrow, December 14, 2010 on the above-entitled
case;
2. That, the undersigned counsel received the Opposition filed by the
Applicant just today, December 13, 2010 at around 3:00 oclock in the
afternoon, more or less;
3. That, the undersigned counsel needs material time to study the Opposition
filed by the Applicant and to correspondingly file its Comment thereon in the
interest of substantial justice to shed light on the issue of the case;
4. That, considering the fact the undersigned counsel received the Opposition
of the applicant just few hours before the scheduled hearing, there is an urgent
need to reschedule the hearing scheduled tomorrow December 14, 2010 to give
chance for the Protestants to file its Comment on the Opposition of the Applicant.
5. That, the filing of this Motion with Manifestation is not intended to delay the
proceedings of this case but is sought in the best interest of justice and equity.

WHEREFORE, premises considered, it is most respectfully prayed before this

Honorable Office to allow and/or give time for the Protestants to file and submit its
Comment on the Opposition filed by the Applicant within 10 days from receipt thereof
and to reschedule the hearing to a different date after the Protestant was able to file its
Comment on the Opposition.
Other reliefs and remedies that may be equitable under the premises
are likewise prayed for.
Most respectfully submitted.
13 December 2010; Malaybalay City.

JENNY UPLINGER SALE

Counsel for the Protestants
Roll of Attorneys No. 56315
IBP (Bukidnon) OR No. 768435 Jan. 4, 2010
PTO (Bukidnon) PTR No. 4744360 Jan.4, 2010
Tax Identification Number 921-274-578
MCLE Compliance Number III 0011693 Issued: April 8,
2010
Contact Details:
Nellas Building, Fortich St., Sayre Highway, Sumpong,
Malaybalay City, Bukidnon, Philippines 8700
Telephone No. (088) 813-3400 | Mobile Phone No. 0917-7072001
Email Address: jusale79_cpa@yahoo.com
NOTICE OF HEARING
To: Office of the Provincial Environment and Natural Resources
Greetings!
In view of the urgency, please take notice that tomorrow, December
14, 2010 at 8:30 in the morning, the undersigned will ask this Honorable
Office, for the hearing and approval of the foregoing motion.

Copy furnished:
Rosalinda L. Hernandez
c/o Atty. Sharon Dablo-Daral, Malaybalay City