Motion For Additional Deposit

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REPUBLIC OF THE PHILIPPINES

Regional Trial Court


12TH JUDICIAL REGION
BRANCH 07
Tubod, Lanao del Norte

NATIONAL GRID SPL. CVL. ACTION


CORPORATION, 12345
Plaintiff,

-versus- For:

Expropriation
XXXX,
Defendants
.
X--------------------------------------------X
x - - - - - - - - - - - - - - - - - - - - - - - - - - - -/

MOTION FOR EXTENSION OF TIME


TO FILE ANSWER

Comes now the defendant XXXX, through the Public


Attorney’s Office and by the undersigned counsel, unto this
Honorable Court, most respectfully states that:

On 09 February 2021, the Honorable Court issued a Writ


of Possession in favor of the plaintiff NGCP in this case.

That the issuance of the Writ of Possession was based on


the 2015 BIR Zonal value for coco lands (A4). However, it
appears that a new and updated BIR Zonal valuation was
issued by the Bureau of Interval Revenue effective 20 October
2020.

In the said new and updated BIR Zonal Valatuations, the


value for coco lands (A4) in Manga, Kolambugan, Lanao del
Norte has increased from Php7.00 per square meter to
Php45.00 per square meter. (Attached and made as an
integral part of this Motion is the said new BIR Zonal
Valuation as ANNEX “A”).

That the amount deposited by the NGCP for the issuance


of the Writ of Possession was only Six Thousand One
Hundred Ninety Three Pesos and Ninety Two Centavos

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(Php 6,193.92) representing the 100% zonal value of the total
affected area of 575 square meters.

That the total amount to be deposited should be Twenty


Five Thousand, Eight Hundred Seventy Five Pesos
(Php25,875.00) under the new BIR zonal valuation.

As such, there is a need for NGCP to provide additional


deposit in the amount of Nineteen Thousand Six Hundred
Eighty One Pesos and Eight Centavos (Php19,681.08).

PRAYER
WHEREFORE, premises considered, it is most
respectfully prayed of this Honorable Court to issue an Order
granting the herein motion and ordering the plaintiff to make
an additional deposit in the amount of Nineteen Thousand
Six Hundred Eighty One Pesos and Eight Centavos
(Php19,681.08)..

All other reliefs and remedies which are deemed just and
equitable under the premises are likewise prayed for.

RESPECTFULLY SUBMITTED,

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