Republic of the Philippines
DEPARTMENT OF JUSTICE
                              National Prosecution Service
                            CITY PROSECUTOR’S OFFICE
                                     Calbayog City
MERIAM FRANCISCO y                                     NPS Docket No. VIII-10-
WENCESLAO,                                             INV-19F-00091
            Complainant,
                                                       - For –
                  - Versus -
                                                       ROBBERY WITH
RONEL RUBANTE @ Onel,                                  HOMICIDE and ROBBERY
Alias BING BING PANZUELO,                              WITH FRUSTRATED
JOSE TANEO @ Osik,                                     HOMICIDE
JOJO DELIQUIÑA,
NOEL PANZUELO @ Bota,
              Respondents.
x-----------------------------------------------------------x
                    JOINT MOTION FOR EXTENSION OF TIME
                        TO SUBMIT COUTER AFFIDAVIT
      The Respondents, unto the Honorable City Prosecutor, most
respectfully state:
     1. On July 09, 2019, we received a subpoena from the City Prosecutor’s
        Office charging us of the above-stated offense and requiring us to
        submit our counter-affidavits and other supporting documents within
        Ten (10) days from receipt thereof;
     2. That on account of our difficulty to engage the services of a counsel,
        we prayed before this Honorable City Prosecutor for an extension of
        time to file counter affidavit, which we submitted last July 18, 2019;
     3. The nature of the offense charged against us is of a crime of utmost
        gravity;
     4. And we are in dire need to further study the case and to gather
        relevant evidence to support our defense and prove our innocence,
        thus, this request for a period of another Ten (10) day extension within
        which to submit the our Counter-Affidavits and other supporting
        documents;
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   5. That the filing of this motion is done in good faith and not for purposes
      of delaying the proceedings of this case but for the reason above-
      stated.
                                  PRAYER
       WHEREFORE, premises considered, we, the Respondents, in the
interest of justice and equity, respectfully prays before the Honorable City
Prosecutor that we be given an additional period of TEN (10) DAYS from
receipt hereof within which to submit our Counter-Affidavits and other
supporting documents.
      Calbayog City, Samar, Philippines, July 29, 2019.
         RONIL RUBANTE                              JOSE TANEO
           Respondent                                Respondent
                     AMADO ‘Bing Bing” PANZUELO
                             Respondent
Copy Furnished:
Meriam Francisco y Wenceslao
Brgy. Tingolon
Isabel, Leyte
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