Republic of the Philippines

Sixth Judicial Region

FIRST MUNICIPAL CIRCUIT TRIAL COURT OF
_________________________________
________________________

_____________________________.,
Plaintiffs,
- versus - CIVIL CASE No. _________

____________________________., FOR: OWNERSHIP, QUIETING

OF TITLE AND DAMAGES
Defendants.
x-------------------------
- - -x

COMMENT TO MOTION TO DISMISS WITH

ENTRY OF APPEARANCE
PLAINTIFFS, through counsel, and unto this Honorable Court, most
respectfully avers:

1. That the Honorable Court sent an Order to herein Plaintiffs giving them
15 days from receipt of said Order to file their comment to the pending
Motion to Dismiss filed by herein Defendants;

2. That said Order was received by herein Plaintiffs on December 14, 2018,
hence they still have until December 29, 2018, to file their comment;

3. The Plaintiffs respectfully opposes the Defendants Motion to Dismiss; for

the Plaintiffs were caught off guard and was confused by the sudden, hasty
and abrupt retirement and withdrawal of their previous counsel, said
circumstance gave the Plaintiffs difficulty in retrieving the records of their
case from said counsel and was also financially unprepared for the
unexpected cost of hiring the services of a new counsel;

4. That it was only recently, around the first week of December 2018 that
the services of the undersigned had been engaged to represent herein
Plaintiffs in the instant case and as such, it is hereby requested that all
notices, orders and other judicial processes emanating from this
Honorable Court be forwarded unto the undersigned counsel at his
address hereinbelow cited;
 PRAYER

WHEREFORE, premises duly considered, and in the interest of equity

and substantial justice, it is respectfully prayed that the Motion to Dismiss moved
by herein Defendants be denied;

That it is also prayed for that the entry of appearance of the undersigned
counsel for the Plaintiffs be noted;

Other reliefs, just and equitable, under the foregoing premises, are likewise
prayed for.

_________________, January 2, 2019.

___________________________.
Counsel for the Plaintiffs

Copy Furnished by personal delivery:

____________________________
Counsel for the Plaintiffs
Kalibo, Aklan