MOTION FOR RECON Diego Malacad

REPUBLIC OF THE PHILIPPINES
Department of Transportation and communications

LAND TRANSPORTATION FRANCHISING AND REGULATORY
BOARD
Region VI, Iloilo City
NEGROS BACOLOD DELTA CASES NO.:

TRANSPORT OPC , duly
represented by DIEGO G. 1.) BEO-2012-VI-039;
MALACAD, 2.) RVI-EV-PJ-2018-01-07-476-NOC;
Applicant. 3.) RVI-EV-PJ-2017-EO11-158-NOC;
4.) RVI-EV-19-2017;
APPLICATION FOR 5.) RVI-EV-PJ-2020-08-10-067-NOC;
CONSOLIDATION OF 6.) E010-495;
CERTIFICATES OF PUBLIC 7.) RVI-EV-PJ-2017-12-E014-544;
CONVENIENCE TO OPERATE 8.) 10-097-NOC;
PUBLIC UTILITY JEEPNEYS.
x---------------------x
MOTION FOR RECONSIDERATION
COMES NOW, Applicant, through the undersigned Counsel, unto

this Honorable Board, most respectfully alleges, THAT:
1. Applicant Negros Bacolod Delta Transport OPC, hereby submit

this Motion for Reconsideration regarding the attached Application
Consolidation dated May 10, 2024;
2. The subject Application for Consolidation was not filed on or

before the April 30, 2024 deadline, as mandated by the LTFRB. This delay
was due to the financial constraints faced by our operators, who were
unable to immediately pay the required penalties;
3. The Applicant understands the importance of complying with the

established deadlines and the need to ensure the orderly and efficient
management of public transportation services. However, the Applicant
would like to respectfully request your consideration of the unique
circumstances that led to the late filing of our Application for Consolidation;
4. The Applicant and the affected operators of Negros Bacolod Delta

Transport OPC have been facing significant financial challenges in the
aftermath of the COVID-19 pandemic, which has had a profound impact on
the public transport industry. The reduced ridership and operational
restrictions have severely strained the financial resources of our company,
Page 2 of 3
===========================
making it difficult to immediately meet the penalties required for the timely
submission of our consolidation application; and
5. Despite these challenges, the Applicant and the affected

operators are committed to providing reliable and efficient public
transportation services to the residents of Bacolod City specifically the
Fortune Towne-Central Market Route. The Applicant firmly believes that
the consolidation of our authorized units will enable us to better serve the
commuting public, improve the quality of our services, and ensure the
continued viability of our operations.
PRAYER
WHEREFORE, the Applicant humbly requests to grant the subject

Motion for Reconsideration and accept the attached Application for
Consolidation, even though it was filed after the April 30, 2024 deadline.
The Applicant is prepared to immediately pay the required penalties upon
the approval of this motion, and the Applicant assures the LTFRB that,
together with the affected operators, it will work diligently to comply with all
other LTFRB rules and regulations going forward.
Other remedies that are just and equitable under the premises are
hereby prayed for.
Iloilo City, Philippines. _____________
ATTY. FRANCIS LEO J. TIANERO

Counsel for the Applicant
Door 1, Mezzanine Floor, Daclis Building
Bonifacio Drive, Iloilo City
PTR No. 8336859/Iloilo City/01/02/24
IBP No. 328092/(Online)/Pasig
City/12/14/23
Roll No. 87637
MCLE Initial Compliance
Valid Until April 14, 2025
eMail: [email protected]
Mobile No.: 09478911257
Page 3 of 3
===========================
VERIFICATION AND CERTIFICATION

AGAINST FORUM-SHOPPING
I, DIEGO G. MALACAD, of legal age, married, Filipino Citizen and a
resident of Lucky Homes Subdivision, Handumanan, Bacolod City, after
having been duly sworn in accordance with the law do hereby depose and
say that:
1. I am the duly representative of NEGROS BACOLOD DELTA

TRANSPORT OPC with office address at Freedom Road, Lucky Homes
Subdivision, Handumanan, Bacolod City;
2. I caused the preparation of the foregoing Motion for

Reconsideration;
3. I have read the same and all allegations contained therein are
true and correct of my personal knowledge and/or based on authentic
documents and records;
4. I have not theretofore commenced any action or filed any

application involving the same issues with this Honorable Board, court,
tribunal or quasi-judicial agency and, to the best of our knowledge, no such
other petition/application is pending therein;
5. If I should thereafter learn that the same or similar application

has been filed or pending, we shall report that fact within five (5) calendar
days to this Honorable Board wherein this petition is pending.
DIEGO G. MALACAD
Affiant
ID: BIR TIN ID Card
TIN: 134-331-073
SUBSCRIBED AND SWORN TO before me in Iloilo City this

__________ by the above-mentioned affiant, who has satisfactorily proven
to me his identity through his competent identification document with its
particulars appearing below his signature and printed name to be the
person who presented and personally signed before me this
VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING
and attested that the contents thereof are true and correct; and he
voluntarily executed the same.
Doc. No. : ________;

Page 4 of 3
===========================
Page No. : ________;
Book No. : ________;
Series of 2024.

MOTION FOR RECON Diego Malacad

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REPUBLIC OF THE PHILIPPINES

Department of Transportation and communications

NEGROS BACOLOD DELTA CASES NO.:

MOTION FOR RECONSIDERATION

COMES NOW, Applicant, through the undersigned Counsel, unto

1. Applicant Negros Bacolod Delta Transport OPC, hereby submit

2. The subject Application for Consolidation was not filed on or

3. The Applicant understands the importance of complying with the

4. The Applicant and the affected operators of Negros Bacolod Delta

5. Despite these challenges, the Applicant and the affected

WHEREFORE, the Applicant humbly requests to grant the subject

Iloilo City, Philippines. _____________

ATTY. FRANCIS LEO J. TIANERO

VERIFICATION AND CERTIFICATION

1. I am the duly representative of NEGROS BACOLOD DELTA

2. I caused the preparation of the foregoing Motion for

4. I have not theretofore commenced any action or filed any

5. If I should thereafter learn that the same or similar application

SUBSCRIBED AND SWORN TO before me in Iloilo City this

Doc. No. : ________;

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