Republic of the Philippines

DEPARTMENT OF TRANPORTATION AND COMMUNICATIONS

Cordillera Administrative Region
Baguio City
LAND TRANSPORTATION FRANCHISING AND REGULATORY
BOARD

PETITION FOR DROPPING AND

SUBSTITUTION OF A CERTIFICATE OF
PUBLIC CONVENIENCE TO OPERATE A
UV EXPRESS SERVICE
CASE NO: 2016- CAR- 118
JONATHAN LABI
Petitioner
x---------------------------------------------x

PETITION

WITH ALL DUE RESPECT TO THE HONORABLE BOARD.

Petitioner by and through the undersigned, come unto this Honorable Board and
most respectfully states, that:

1. The Petitioner is of legal age, Filipino, married, and a resident of Abatan,

Buguias, Benguet;

2. That Petitioner is a grantee of a Certificate of Public convenience to operate a

UV EXPRESS SERVICE on the line: LA TRINIDAD- BUGUIAS AND VICE VERSA,
under LTFRB CASE NO: 2016-CAR-118; as evidenced by hereto attached Decision
issued by this Honorable Board, with the use of one (1) unit authorized unit described
hereunder;

MAKE: MOTOR NO. CHASSIS NO. PLATE NO.

Hyundai D4BFP646237 KMJRD37FPPU051021 AYR589

3. Furthermore, in order that public convenience and necessity will be served and
promoted in the most suitable and appropriate manner, the Petitioner intend to drop and
substitute the above-described unit with the latest model which is more road worthy and
convenient for the riding public. Said incoming unit is particularly described as follows:

MAKE MOTOR NO. CHASSIS NO. PLATE NO. MODEL

Toyota 1KD2690884 JTFRT13P3H8011690 ----------- 2017

4. The Petitioner is legally and financially capable to maintain and operate the
service; and

5. The public convenience and necessity will be served and promoted in the most
suitable and appropriate manner with the approval of the instant petition, and that the
Petitioner will abide to all laws, rules, and regulations pertinent to the operation of the
service and will comply with all other requirements as may be required from time to time.

6. Petitioner respectfully prays to the Honorable Board to approve and grant the
foregoing as the same is necessary and essential due to the increasing public need for
transportation services on the aforesaid line.
 WHEREFORE, premises considered, it is most respectfully prayed of the
Honorable Board approving the foregoing petition for dropping and substitution of a UV
EXPRESS SERVICE.

Other relief and remedies under the premises are likewise prayed for.
Respectfully submitted this 9th day of March 2017, in the City of Baguio,
Philippines.

LILIBETH B. COSI
IBP NO.: 1056762; 01-03-2017; Baguio City
PTR NO.: 2923985; 01-03-2017; Baguio City
ROLL NO. 60859; 03-26-2012
MCLE NO: V-0008679
B3 Telof Building, LTO Compound
Leonard Wood Road Baguio City

VERIFICATION / CERTIFICATION OF
NON-FORUM SHOPPING

I, JONATHAN LABI, of legal age, married, Filipino citizen, and a resident of

Abatan, Buguias, Benguet, after having been sworn to in accordance with law depose
and state that:

I am the petitioner in the instant Petition for the Dropping and Substitution of
Certificate of Public Convenience to operate a UV EXPRESS SERVICE, under the
above entitled case;

I caused the preparation and filing of the foregoing Petition and that all the
allegations therein contained are true and correct to the best of my own personal
knowledge and based on authentic records;

That I hereby further certify that I have not commenced nor filed any application,
petition or other pleading involving the same issues in any other LTFRB Office and, to
the best of my knowledge, no such other application, petition or pleading is pending
therein; and

That should I learn of the same or similar application, petition or pleading has
been filed or is pending, I undertake to report of such fact within five (5) days therefrom
to the LTFRB Office where my applicatio n, petition or pleading has been filed.

IN WITNESS WHEREOF, I hereunto set my hands this 9 th day of March 2017 at

Baguio City, Philippines.

JONATHAN LABI
Petitioner
PDL No: B04-07-005039

SUBSCRIBED AND SWORN, to before me this 9th day of March 2017 at Baguio
City, Philippines, applicant exhibiting his Driver's license identification number with
numbers indicated below her name and signature.

WITNESS MY HAND AND NOTARIAL SEAL.

Doc. No. ____;
Page No. ____;
Book No. ____;
Series of :_____.
Republic of the Philippines)
City of Baguio . . . . . . . . . )s.s

AFFIDAVIT
(In Support of Formal Offer of Evidence)

I, JONATHAN LABI, of legal age, married, Filipino citizen, and a resident of

Abatan, Buguias, Benguet, after having been sworn to in accordance with law depose
and state that::

1. I am the petitioner in the instant Petition for the Dropping and Substitution of
Certificate of Public Convenience to operate a UV EXPRESS SERVICE, under the
above entitled case;

2. I am legally and financially capable to maintain and operate the above

mentioned service and willing to comply with all the rules and regulations as well as the
conditions prescribed by the Land Transportation franchising and Regulatory Board;

3. Public convenience and necessity will be better served in a proper and suitable
manner with the approval of the instant application;

4. I am adopting the summary hearing procedure before the LTFRB-DOTC-CAR

and move that the instant petition/application be approved.

AFFIANT FURTHER SAYETH NAUGHT.

JONATHAN LABI
Petitioner
PDL No: B04-07-005039

SUBSCRIBED AND SWORN, to before me this 9th day of March 2017 at Baguio
City, Philippines, applicant exhibiting his Driver's license identification number with
numbers indicated below her name and signature.

WITNESS MY HAND AND NOTARIAL SEAL.

Doc. No. ____;
Page No. ____;
Book No. ____;
Series of :_____.
 Republic of the Philippines
DEPARTMENT OF TRANPORTATION AND COMMUNICATIONS
Cordillera Administrative Region
Baguio City
LAND TRANSPORTATION FRANCHISING AND REGULATORY
BOARD

PETITION FOR DROPPING AND

SUBSTITUTION OF A CERTIFICATE OF
PUBLIC CONVENIENCE TO OPERATE A
UV EXPRESS SERVICE
CASE NO: 2016- CAR- 118
JONATHAN LABI
Petitioner
x---------------------------------------------x

FORMAL OFFER OF EVIDENCE

Petitioner through counsel, and unto the Honorable Board most respectfully
submits in evidence the foregoing documentary exhibits duly marked, to form part of the
testimonies of the Petitioner and/or witnesses to wit:

EXHIBIT A - The petition duly received by the Board

EXHIBIT B - OR/CR of authorized out unit
EXHIBIT C - OR/CR of authorized new unit
EXHIBIT D - Copy of the Decision
EXHIBIT E - Pictures of Out Unit
EXHIBIT F - Pictures of IN Unit
EXHIBIT G - Operators Data Sheet

WHEREFORE, it is respectfully prayed of the Honorable Board to admit the

foregoing exhibits for the purpose they are being offered and for such other purposes
that may be worth in proving the petitioners case. With their admission, petitioner rests
his case and reiterates the approval of his petition.

RESPECTFULLY SUBMITTED.

ATTY. LILIBETH B. COSI

Counsel for Petitioner
PETITION FOR DROPPING AND
SUBSTITUTION
OF A CERTIFICATE OF PUBLIC
CONVENIENCE
TO OPERATE
A UV EXPRESS SERVICE

CASE NO: 2016-CAR-118

JONATHAN T. LABI
Petitioner

ATTY. LILIBETH B. COSI

Counsel
 Republic of the Philippines
DEPARTMENT OF TRANSPORTATION AND COMMUNICATION
Cordillera Administrative Region
Baguio City

LAND TRANSPORTATION FRANCHISING AND REGULATORY

BOARD

THE CLERK
Land Transportation Franchising and Regulatory Board
DOTC- CAR
Pacdal, Baguio City

Greetings!

Please enter the apperance of the undersigned as counsel for the

petitioner/applicant in the case of JONATHAN LABI, Petitioner/Applicant for the Petition
for the Dropping and Substitution of a Certificate of Public Convenience to operate a UV
EXPRESS Service,

It is further prayed that henceforth, all processes relative to the afrementioned

case should be addressed to the undersigned counsel in her office address herein
indicated.

Respectfully submitted this 9th day of March 2017

Baguio City, Philippines

LILIBETH B. COSI
IBP NO.: 1056762; 01-03-2017; Baguio City
PTR NO.: 2923985; 01-03-2017; Baguio City
ROLL NO. 60859; 03-26-2012
MCLE NO: V-0008679
B3 Telof Building, LTO Compound
Leonard Wood Road Baguio City