Republic of The Philippines Fourth Judicial Region Regional Trial Court Branch 21, Imus City, Cavite

Balunos, Arron
Activity No. 5
MOTIONS
1. MOTION FOR ISSUANCE OF HOLD DEPARTURE ORDER- A

motion which may be filed by the Complainant through his Counsel under
the control and supervision of the Public Prosecutor with the court (RTC or
Sandiganbayan) having jurisdiction over the place where the crime was
committed against a party or a foreign national who is charged with a crime
where the penalty prescribed by law is at least six (6) years and one (l) day
to prevent the respondent from leaving the Philippines. The primary
objective is to ensure that the party that is the subject of the HDO or
precautionary HDO is brought to the court’s jurisdiction to face the charges
against him.
Republic of the Philippines
Fourth Judicial Region
REGIONAL TRIAL COURT
Branch 21, Imus City, Cavite
REPUBLIC OF THE PHILIPPINES,
Complainant,
-versus- CRIMINAL CASE NO. 9935-11
FOR: Qualified Theft
JASPER SOL CRUZ,

Accused.
x - - - - - - - - - - - - - - - - - - - - - - - - -x
MOTION FOR ISSUANCE

OF A HOLD DEPARTURE ORDER
Private Complainant, by counsel, under the direct control and
supervision of the Honorable Public Prosecutor respectfully alleges that:
This is a criminal complaint for Qualified Theft under the Revised Penal Code
against the accused.
Private complainant has reliable information that said accused is intending to
go abroad to evade criminal prosecution.
Consequently, to insure that accused do not leave the country to evade
criminal prosecution and to guarantee that he is properly brought before the
bar of justice to face his charge, it becomes imperative that he be placed in the
“hold departure order” list of the Bureau;
For the guidance and information of the Court, we furnish the complete data,
regarding accused JASPER SOL CRUZ to wit;
Complete Name : JASPER SOL CRUZ
Sex : male
Civil Status : Separated
Complete Address : No. 866 W. Cornetto Street,
Malibay, Pasay City
Date of Birth : May 18, 1958
Birthplace : Tanauan, Batangas
Age : 54 years old
Photocopy of the photograph of the JASPER SOL CRUZ is hereto
attached as Annex “A” for easy reference.
WHEREFORE, premises considered, it is respectfully prayed that this
Honorable Court issue an order directing the Commissioner of the Bureau of
Immigration to place
Other relief and remedies just and equitable under the premises are
prayed for.
City of Manila, for Imus City, 25 July 2011.
PARIL LAW OFFICE
Counsel for Private Complainant
1080 Negros Street, Balic- Balic
Sampaloc, Manila
by:
JEFFREY PARIL
IBP#941296, Sampaloc Chapter, 12-27-2010
PTR#176413, Sampaloc, Manila, 1-2-2012
Attorney’s Roll No. 48000
MCLE Compliance No. II- 0009569
MCLE Compliance No. III- 0000923
MCLE Compliance No. IV- 0007733
With my conformity and
Under my control and supervision:
PROSECUTOR JACK MIOF
Asst. City Prosecutor
Notice
Office of the City Prosecutor
Imus City, Cavite
CLERK OF COURT
Regional Trial Court
Branch 21, Imus City

ATTY. RAPHAEL CORONADO
2nd Floor, RCVJ Building,
Don P. Campa Avenue, Barrio Uno,
2662 Dasmarinas City, Cavite
ATTY. ALEXANDER LIQUIGAN
Unit 3C, De Quiroz Bldg.,
Aguinaldo Highway, Perpetual Village,
Palico III, Imus City, Cavite
Greetings:
Please be notified the undersigned has requested the Branch Clerk of Court to
include the foregoing Motion in the Court Calendar on August 23, 2011 at
8:30 a.m. that counsel and matter may be heard.
JEFFREY PARIL
Copy furnished:
Imus City, Cavite
Explanation
Copy of the Motion was furnished to the respondent by private courier due to
the distance of the undersigned from the said parties, making personal service
thereof not practicable.
JEFFREY PARIL
2. MOTION FOR LEAVE OF COURT TO FILE DEMURRER TO

EVIDENCE- A motion for Leave of Court to file Demurrer to Evidence is filed
before the Demurrer to Evidence is filed. Demurrer to Evidence is basically a
motion to dismiss on the ground of insufficiency of evidence. It is a remedy
available to the accused to test the sufficiency or insufficiency of the prosecution’s
evidence against him/her.
Rule 119, Section 23 of the Rules of Court states that Demurrer to Evidence may
be filed with or without leave of court. If the Court denies the demurrer to evidence
filed without leave of court, the accused waives the right to present evidence and
submits the case for judgment on the basis of the evidence for the prosecution. But
if it is denied with leave of court, the accused may adduce evidence in his defense.
The motion for leave of court to file demurrer to evidence shall specifically state
its grounds and shall be filed within a non-extendible period of five (5) days after
the prosecution rests its case. The prosecution may oppose the motion within a
non-extendible period of five (5) days from its receipt. If the leave of court is
granted, the accused shall file demurrer to evidence within a non-extendible period
of ten (10) days from notice. The prosecution may oppose the demurrer to
evidence within a similar period from its receipt.
REGIONAL TRIAL COURT OF ZAMBOANGA DEL NORTE
9th Judicial Region
DIPOLOG CITY
Branch VI
PEOPLE OF THE PHILIPPINES,
Plaintiff Criminal Case No. 77
-versus-
for- Murder
JUAN DE LA CRUZ,
Accused
x--------------------------x
MOTION FOR LEAVE TO FILE
DEMURRER TO EVIDENCE
The accused through counsel, unto this Honorable Court, most
respectfully states:
1. That the prosecution in the above entitled case has already rested its
case;
2. That the defense believes that the evidence of the prosecution
against the accused is insufficient to establish the guilt of the accused beyond
reasonable doubt, thus, the defense prays for leave to file demurrer to evidence
in accordance with Section 33, Rule 113 of the Rules of Criminal Procedure.
WHEREFORE, premised on the foregoing consideration and in the
highest interest of justice, it is most respectfully prayed of this Honorable Court
that the aforesaid motion be granted.
September 16, 2010. Dipolog City, Philippines.
3.MOTION FOR BILL OF PARTICULARS - A motion which may be filed

before rendering a respond to a pleading to amplify or limit a pleading, specify
more minutely and particularly a claim or defense set up and pleaded in general
terms, give information, not contained in the pleading, to the opposite party and the
court as to the precise nature, character, scope, and extent of the cause of action or
defense relied on by the pleader, and apprise the opposite party of the case which
he has to meet, to the end that the proof at the trial may be limited to the matter
specified, and in order that surprise at, and needless preparations for, the trial may
be avoided, and that the opposite party may be aided in framing his answering
pleading and preparing for trial.
Branch 47
Puerto Princesa City, Palawan
ALEX BERMEJ
Plaintiff, Civil case No. 5524
-versus-
FOR: DAMAGES
ROEL PONCE DE LEON
Defendant
x --------------------------------------x
MOTION FOR BILL OF PARTICULARS
Defendant, by counsel and to this Honorable Court, respectfully

states:
1. The complaint alleges that defendant public official, together with
herein defendant movant, acting singly or collectively, and or in
unlawful concert with one another, in flagrante breach of public trust
and of sheer fiduciary obligations as public officers with gross and
scandalous abuse of right and power and in brazen violation of the
Constitution and laws of the Philippines, embarked upon a systematic
plan to accumulate ill-gotten wealth.
2. The foregoing allegations are conclusions of law, which plaintiff
should clarify and flesh them with facts and specific acts to enable
defendant-movant to prepare and file a responsive answer thereto
which requires information as to precise nature, character, scope and
extent of plaintiff’s cause of action.
WHEREFORE, defendant prays that plaintiff be ordered to file a bill of
particulars of the facts and acts constituting the conclusions alleged in the
complaint.
ATTY. PERCIVAL JAMES L.
LACEBAL
Counsel for the Defendant
NOTICE OF HEARING
Atty. Juan S. Magbanua
Counsel for the defendant
Bgy. San Pedro, Puerto Princesa City
Sir:
Please be informed that the undersigned counsel has set the foregoing
Motion for Reconsideration for hearing on November 25, 2013 at 8:30 am, forthe consideration of the
Honorable Court or soon thereafter as counsel maybe
heard.
ATTY. PERCIVAL JAMES L.
LACEBAL
Counsel for the Plaintiff
Bgy. Sta. Monica. Puerto Princesa
City
AFFIDAVIT OF PERSONAL SERVICE
I, RUBEN R. PADILLA, of legal age and having been duly sworn
depose and say:
That I am the messenger of Atty. Arnel B. Venturillo, Counsel for the
defendant in the case entitled Alexander Bermejo vs. Roel Ponce de Leon, Civil
Case No. 65448, and that such messenger I served upon the counsel of adverse
party and other parties, the Motion for Consideration filed in said case, as
follows:
Atty. Bernardo U. Goy, counsel for the Plaintiff, by personal service
by delivering personally copy of said Motion upon said lawyer who
acknowledged receipt there of as shown by his signature or initial on the said
pleading, this 23rd day of October 2013
IN WITNESS WHEREOF, I have signed this affidavit this 24th day
of October 2013 at Puerto Princesa City.
Ruben R. Padilla
Affiant
SUBSCRIBED AND SWORN TO BEFORE ME, A Notary public
in and for the City of Puerto Princesa and the Province of Palawan this 24 th day
of October 2013. Affiant personally came and appeared with Driver’s License
ID No. issued by the Land Transportation Office and valid until May 1, 2015,
at Puerto Princesa City, bearing his photograph and signature, known to me as
the same person who personally signed the foregoing instrument before me and avowed under penalty of
law to the whole truth of the contents of said
instrument
ATTY. PERCIVAL JAMES L. LACEBAL
Notary Public
Doc. No. ______;
Page No. ______;
Book No. ______;
Series of 2013;
Copy furnished:
Atty. Marilen Saniel
Counsel for plaintiff
Bgy. San Pedro, PPcity
4. MOTION FOR CONSOLIDATION OF CASES - A motion requesting the

court to consolidate cases arising from the same incident or series of incidents, or
involving common questions of fact and law.
REPUBLIC OF THE PHILIPPINES
National Capital Judicial Region
BRANCH 113
Pasay City
RAPHAEL ENRIQUE V. CORONADO,
Petitioner,
-versus-
CIVIL CASE NO. C-QTZ-24-25285-D
For: Declaration of Nullity of Marriage
ELLEN A. ADARNA,
Respondent
x------------------------------------------x
EX PARTE MOTION FOR CONSOLIDATION OF CASES
Petitioner, by counsel, to this Honorable Court respectfully states:
This is a Petition for Declaration of Nullity of Marriage which was filed on 26
June 2013.
On the same date, a Protection Order with application for TPO and Support
Pendente Lite pursuant to Administrative Matter No. 04-10-11-C or the Rules
on Violence Against Women and Their Children Act involving the abovementioned
parties was filed and raffled before the Regional Trial Court of
Pasay City Branch 113 with Civil Case no. BCV 2013-84.
That the two petitions involve the same parties with intertwined issues and
subject matters.
WHEREFORE, it is respectfully prayed that an order be granted to
consolidate the two actions in the Regional Trial Court Branch 113, Pasay
City where the declaration of nullity of marriage was raffled which may tend
to avoid unnecessary costs or delay and to serve the best interests of the
parties and to settle expeditiously the issues involved
Imus City for Pasay City, 7 July 2013.
LOMIBAO LAW OFFICE
406 Violago Homes, Litex, Quezon City
Tel. No. 0917- 8032- 788
Email Add.: LLawOffice@yahoo.com
by:
RICA KAYE O. LOMIBAO
IBP No. 119739 CAVITE CHAPTER
PTR No. 3181314, Imus City, 1-11-12
MCLE Compliance No. VI-1111201
Notice
THE CLERK OF COURT
RTC Branch 113
Pasay City
Greetings:
Please submit the foregoing motion for the consideration and
approval of the Honorable Court immediately upon receipt hereof.
5. MOTION FOR PERMANENT DISMISSAL- a motion requesting the court to

permanently dismissed the case filed when the prosecution has not instituted any
action to revive the case after the lapsed of one year. Under the Rules on Criminal
Procedure, the provisional dismissal of the offenses punishable by imprisonment
not exceeding six (6) years, shall become permanent one (1) year after the issuance
of the order without the case having been revived.

Complainant,
JASPER SOL CRUZ,
Accused.
x - - - - - - - - - - - - - - - - - - - - - - - - -x
MOTION FOR PERMANENT DISMISSAL
ACCUSED, by the undersigned counsel, unto this Honorable Court,
most respectfully states that:
1. On 02 September 2012, an Order was issued by this Honorable Court
dismissing the case provisionally with the expressed conformity of the
accused. Attached is a copy of the said Order hereto marked as Annex "1" and
forms and integral part hereof;
2. Under the Rules on Criminal Procedure, the provisional dismissal of the
offenses punishable by imprisonment not exceeding six (6) years, shall
become permanent one (1) year after the issuance of the order without the
case having been revived;
3. A year had already lapsed, and the prosecution has not instituted any
action to revive the case; hence, accused respectfully moves that the case be
permanently dismissed.
PRAYER
WHEREFORE, premises considered and in the interest of justice, it is
respectfully prayed that the Honorable Court render the case permanently
dismissed.
Other reliefs just and equitable are also prayed for.
Imus City, for Pasay City, 29 December 2013.
BAQUIRAN, CORONADO & RICAFRANCA
Counsel for Accused Jasper Sol Cruz

by:
RAPHAEL ENRIQUE V. CORONADO
Roll No. 690069
IBP No. 990905/ 1-03-2012/Cavite
PTR No. 1678611/ 1-02-2012/Dasmarinas
Notice
Imus City, Cavite
CLERK OF COURT
ATTY. JEFFREY PARIL
Sampaloc, Manila
G r e e t i n g s:
Please submit the foregoing motion for the consideration and approval of the
Honorable Office immediately upon receipt hereof.
Copy furnished:
CLERK OF COURT
ATTY. JEFFREY PARIL
Sampaloc, Manila
6. MOTION FOR CANCELLATION OF LIS PENDENS - A motion filed to

request the court to issue an order to cancel the notice of lis pendens on the subject
property. It is usually filed after the resolution of the case. However, it may also be
filed even before final judgment after proper showing that the notice is for the
purpose of molesting the adverse party, or that it is not necessary to protect the
rights of the party who caused it to be registered.
Branch 47
ALEX BERMEJO,
-versus-
FOR: DAMAGES
ROEL PONCE DE LEON,
Defendant
x--------------------------------------x
MOTION TO CANCEL LIS PENDENS
Plaintiff, by counsel and to this Honorable Court, respectfully states:
1. Defendant caused the annotation or registration of a notice of lis
pendens on the subject matter of the instant suit,
2. 2. Defendant caused the recording of the lis pendens for the purpose of
molesting plaintiff, and the recordal thereof is not necessary to protect his rights
to the property, his right thereto, if any, is only indirect and contingent.
3. The recordal of the lis pendens is prejudicial to plaintiff’s interest to
the property because, being the owner of said property, it is burden and it
restricts its transferability by sale, as no one will buy it during the pendency of
the case and for as long as the lis pendens is not canceled.
RELIEF
WHEREFORE, plaintiff respectfully prays that the notice of lis pendens be
ordered cancelled.
Other just and equitable reliefs are likewise prayed for. City of Puerto Princesa, December 2, 2013
ATTY. FELY Q. BALADAD
Counsel for the plaintiff
Brgy. San Pedro, Puerto Princesa City
Roll No. 75648
IBP No. 0457 - Palawan,
PTR No. 11456788, issued on April 13, 2012,
MCLE Compliance Cert. No. 66587
NOTICE OF HEARING
Atty. Juan S. Magbanua
Counsel for the defendant
Bgy. San Pedro, Puerto Princesa City
Sir:
Please be informed that the undersigned counsel has set the foregoing
Motion for Reconsideration for hearing on November 25, 2013 at 8:30 am, for
the consideration of the Honorable Court or soon thereafter as counsel maybe
heard.
Bgy. Sta. Monica. Puerto Princesa City
AFFIDAVIT OF PERSONAL SERVICE
I, JOSEPH D. DAJAY, of legal age and having been duly sworn depose
and say:
That I am the messenger of Atty. Fely Q. Baladad, Counsel for the
defendant in the case entitled Alexander Bermejo vs. Roel Ponce de Leon, CivilCase No. 65448, and that
such messenger I served upon the counsel of adverse
party and other parties, the Motion for Consideration filed in said case, as
follows:
Atty. Arnel Belarmino, counsel for the Defendant, by personal service
by delivering personally copy of said Motion upon said lawyer who
acknowledged receipt there of as shown by his signature or initial on the said
pleading, this 23rd day of October 2013
IN WITNESS WHEREOF, I have signed this affidavit this 4th day of
November 1 2013 at Puerto Princesa City.
JOSEPH D. DAJAY
Affiant
in and for the City of Puerto Princesa and the Province of Palawan this 3rd day
of November 2013. Affiant personally came and appeared with Driver’s
License ID No. D11-125477 issued by the Land Transportation Office and
valid until May 1, 2015, at Puerto Princesa City, bearing his photograph and
signature, known to me as the same person who personally signed the foregoing
instrument before me and avowed under penalty of law to the whole truth of
the contents of said instrument
Notary Public
Until December 31, 2014
Doc. No. ______;
Page No. ______;
Book No. ______;
Series of 2013;
7. MOTION TO CITE WITNESS FOR CONTEMPT - A motion to cite
witness for contempt is a motion filed by the plaintiff containing a formal charge in
writing addressed before a court of competent jurisdiction to require the respondent
to show cause why he should not be punished for contempt. Such motion must be
based on the following grounds:
1. Misbehavior of an officer of a court in the performance of his official duties or

in his official transactions;
2. Disobedience of or resistance to a lawful writ, process, order, or judgment of a

court;
3. Any abuse of or any unlawful interference with the processes or precoeedinfs of

a court not constituting direct contempt;
4. Any improper conduct tending, directly or indirectly, to impede, obstruct, or

degrade the administration of justice;
5. Assuming to be an attorney or an officer of the court, and acting as such without

authority;
6. Failure to obey a subpoena duly served;
7. The rescue, or attempted reduce, of a person or property in the custody of an

officer by virtue of an order or process of a court held by him.
Branch 47
PEDRO MANZANO
-versus-
For: DAMAGES
JUAN DE CASTRO
Defendant
x --------------------------------------x
MOTION TO CITE WITNESS FOR CONTEMPT
PLAINTIFF, by counsel and to this Honorable Court respectfully
alleges:
1. Plaintiff is of legal age and with residence at 335 Malvar Street,
Puerto Princesa while respondent is also of legal age and wit residence at 433
Rizal Avenue, Puerto Princesa City where he may be serve with summons and
other legal processes.
2. Plaintiff is the Plaintiff I the above –captioned case.
3. On November 3, 20103, upon plaintiff’s application, the curt issued
a subpoena for respondent to appear and testify on December 3, 2013 before
the Honorable Court, and said subpoena was served on him on November 15,
2013 by the sheriff, per letter’s return. Certified true copies of the subpoena and
the sheriff’s return are attached hereto as Annexes “A” and “B”, respectively.
4. Respondent did not honor the subpoena, as he did not appear on the
date, time and place indicated in said subpoena, thereby delaying plaintiff’s
presentation of his evidence, as respondent would have been plaintiff’s last
witness.
WHEREFORE, plaintiff prays that after respondent shall have been

given the opportunity to be heard, judgment be rendered punishing him for
indirect contempt of court for willful defiance and disregard of the subpoena
served on him on November 15, 2013.
Puerto Princesa City, December 12, 2013.
ATTY. PERCIVAL
JAMES L. LACEBAL
Bgy. Tanglaw, Puerto
Princesa City
Roll No. 75648
IBP No. 0457 - Palawan,
PTR No. 11456788, issued
on April 13, 2012,
MCLE Compliance Cert.
No. 66587
VERIFICATION AND CERTIFICATION
AGAINST FORUM SHOPPING
I, PEDRO MANZANO, of legal age and with residence at Lagan St.
Puerto Princesa City, after having been duly sworn, depose and say:
1. That I am the plaintiff in the above entitled complaint.
2. That I have caused the preparation by my counsel of said
complaint.
3. That I have read the allegations therein contained, and that
the same are true and correct of my personal knowledge or
based on authentic records.
4. That I have not theretofore commenced any action or filed
any claim involving the same issues in any court, tribunal or
quasi-judicial agency and, to the best of my knowledge, no
such other action or claim is pending therein; and if I should
thereafter learn that the same or similar action or aclim has been filed or is pending to the court wherein
the aforesaid
complaint or initiatory pleading has been filed.
Witness my hand this 23rd day of October 2013 at Puerto Princesa
City, Palawan.
PEDRO
MANZANO
Affiant
in and for the City of Puerto Princesa and the Province of Palawan this 24 th day
of October 2013. Affiant personally came and appeared with Driver’s License
ID No. issued by the Land Transportation Office and valid until May 1, 2015,
at Puerto Princesa City, bearing his photograph and signature, known to me as
the same person who personally signed the foregoing instrument before me and
avowed under penalty of law to the whole truth of the contents of said
instrument
ATTY. PERCIVAL
JAMES L.
LACEBAL
Notary Public
My commission
expires
on December 31,
2011
PTR No. 906760
issued Jan. 3, 2007
IBP No. 918300 Roll
No. 13466
8. EX PARTE MOTION TO DISMISS - It is an application for a relief in a legal

proceeding brought by one party in the absence of and without representation of
the other party, asking the court for the termination of the case.
BRANCH 113
Pasay City
Petitioner,
-versus-
For: Declaration of Nullity of
Marriage
ELLEN A. ADARNA,
Respondent
x------------------------------------------x
EX-PARTE MOTION TO DISMISS
Petitioner, to the Honorable Court, most respectfully state that:
This is an action for declaration of nullity of marriage filed on 26 June 2013
on the ground of psychological incapacity of the respondent.
Without the knowledge of the petitioner, respondent filed a declaration of
nullity of marriage based on Article 35,par (4) of the Family Code on
bigamous and polygamous marriage before the Regional Trial Court (Branch
143) of Urdaneta City, Pangasinan.
Then sometime in November 2013, petitioner received a copy of the Decision
in the said case filed by respondent the dispositive portion of which states:
WHEREFORE, premises duly considered, the marriage BETWEEN
RAPHAEL ENRIQUE V. CORONADO and ELLEN A. ADARNA is hereby
declared void from the very beginning.
SO ORDERED.
PRISCILLA ALMEDA
Presiding Judge
Upon verification with the aforesaid Honorable Court, the said DECISION is
now already final and executory.
Thus, petitioner is constrained to move for the dismissal of this case due to the
aforesaid reason.
Other reliefs as are just and equitable under the circumstances are likewise
prayed for.
Pasay City, February 14, 2014.
Petitioner
NOTICE
The Clerk of Court
RTC-Branch 113
Pasay City
G R E E T I N G S:
Please submit the foregoing ex parte motion for the consideration and
RAPHAEL ENRIQUE V.
CORONADO
Copy furnished:
HON. SOLICITOR GENERAL
134 Amorsolo St., Amorsolo Bldg.,
Legaspi Village, Makati City
OFFICE OF THE CITY PROSECUTOR

Pasay City
ELLEN A. ADARNA
316 Palin St., Block 27 Lot 77
Ai- Ai, General Tinio, GMA, Cavite
Explanation
This Ex Parte Motion to Dismiss is being filed, with copy thereof
furnished the other party, to the Office of the Solicitor General by registered
mail due to the distance of the undersigned from the said other party, making
personal filing and service thereof not practicable.
9. MOTION TO INHIBIT - It is an application for a relief in a legal proceeding

praying that a judge or any officer be restrained from resolving a complaint or a
case.
Department of Justice
Hall of Justice Compound, Aguinaldo Highway, Imus City
Complainant,
JASPER SOL CRUZ,
Accused.
x - - - - - - - - - - - - - - - - - - - - - - - - -x
MOTION TO INHIBIT
Complainant, by counsel, to the Honorable Court, alleges that:
The instant complaint was filed sometime in 06 May 2011. However, up to
this time, no resolution has yet been issued by the honorable office;
This has been the case despite several follow-ups made by the complainant
and it is very apparent that there is an unreasonable delay in rendering the
resolution to the extreme prejudice of the complainants;
In view of the foregoing, to avoid the appearance of bias and impropriety, it is

most respectfully prayed of the Honorable Office that the honorable
investigating prosecutor inhibit himself from resolving this criminal
complaint.
Other reliefs just and equitable are likewise prayed for.
City of Manila, for Imus City, 25 May 2012.
PARIL LAW OFFICE
Sampaloc, Manila
by:
JEFFREY PARIL
Copy Furnished:
Imus City, Cavite
Don P. Campa Avenue, Barrio Uno, 2662 Dasmarinas City, Cavite
EXPLANATION
The foregoing motion is being served to the other party by registered
mail due to distance and lack of office personnel to effect personal service
thereof.
10. MOTION TO LIFT ORDER OF ARREST - It is a motion to lift the order of

the arrest due to the failure of the accused to appear on the scheduled hearing
despite due notice because of some reasonable causes.
Complainant,
JASPER SOL CRUZ,
Accused.
x - - - - - - - - - - - - - - - - - - - - - - - - -x
MOTION TO LIFT ORDER OF ARREST
Accused Jasper Sol Cruz, by counsel, to the Honorable Court, most
respectfully states that:
That on 20 November 2013, the Honorable Court ordered the arrest of the
accused for her failure to appear during the scheduled hearing on the same
date despite due notice;
With the kind indulgence of this Honorable Court, the accused did not neglect
her appearance and to refuse and disobey the lawful orders of this Honorable
Court. However, due to the fact that he was indisposed on the said hearing
date, he failed to appear before this Honorable Court. Moreover, accused
hereby undertakes to attend on the said hearing date;
The filing of this motion is not in any manner intended to delay the
proceedings and early resolution of the above- captioned case but is solely for
the reasons above-stated;
RELIEF
IN VIEW WHEREOF, it is respectfully prayed of this Honorable Court that
the instant motion be granted and the Order of Arrest dated 20 November
2013, be lifted.
Accused prays for such other reliefs as are just and equitable under the
circumstances.
Dasmarinas City, for Imus City, 13 December 2013.
by:
Roll No. 690069
IBP No. 990905/ 1-03-2012/Cavite
Notice of Hearing
Imus City, Cavite
CLERK OF COURT
ATTY. JEFFREY PARIL
Sampaloc, Manila
G r e e t i n g s:
Please submit the foregoing Motion to Lift Order of Arrest and kind
consideration of the Honorable Court immediately upon receipt hereof.
RAPHAEL ENRIQUE V.
CORONADO
Copy furnished:
Imus City, Cavite
ATTY. JEFFREY PARIL
Sampaloc, Manila

11. MOTION TO RELEASE MOTOR VEHICLE – A motion where the police,

pending investigation collects the motor vehicle which is relevant for investigation
during the case and thereafter keeps the same. The owner of this vehicle or
property in order to get the same released from the court has to apply to court and
seek its release as per the conditions which may be imposed on the owner. He has
to file an application before the court in order to seek release of his vehicle. This is
called superdari. The Court may then make an order for proper custody of vehicle
or other such property for the period of inquiry or when trial is pending before the
court.
Complainant,
JASPER SOL CRUZ,
Accused.
x - - - - - - - - - - - - - - - - - - - - - - - - -x
MOTION TO RELEASE MOTOR VEHICLE
Accused, by counsel, to this Honorable Court respectfully states:

That in the hearing for the Petition for Bail held last 12 December 2013, it
was admitted by PO1 Engelbert Villafranca, one of the arresting officers, that
a motor vehicle with body number LBI-XX3499tt and bearing plate number
DUO 789 belonging to the accused is in police custody.
Accused maintained that the impounded motor vehicle was not used in the
commission of the offense, nor was it included in the inventory of confiscated
items from the accused as admitted by the prosecution witness PO2
Villafranca during the 12 December hearing.
With all due respect, it is illogical to confiscate, much more retain custody,
over the said vehicle, when the same was not even included in the inventory
of property confiscated from the accused.
Truth to tell, the said motor vehicle was being used by the accused to earn a
living and that it was never intended to be used for any illegal purpose;
The continued impounding of said vehicle has directly or indirectly deprived
the accused of its work-related and personal use and has impaired his capacity
to earn.
In addition, continued impounding of said vehicle needless to state, would
further caused its deterioration beyond repair.
PRAYER
WHEREFORE, premises considered, it is respectfully prayed that an Order be
issued directing PO2 Engelbert Villafranca to turn over the possession of the
said vehicle to the accused or his duly authorized representatives in the
interest of justice.
Other reliefs, which are just and equitable, are also prayed for.
Dasmarinas City, for Imus City, 13 January 2014.

by:
Roll No. 690069
IBP No. 990905/ 1-03-2012/Cavite
Notice of Hearing:
CLERK OF COURT
G r e e t i n g s:
Please submit the foregoing motion for the consideration and approval of the
Honorable Court on January 25, 2014 at 1:30 p.m. or at such time and date as
may be convenient to the Honorable Court.
RAPHAEL ENRIQUE V.
CORONADO
Explanation
Copy of the Motion was furnished to the defendant by private courier due to
the distance of the undersigned from the said party, making personal service
RAPHAEL ENRIQUE V.
CORONADO
Copy furnished:
Imus City, Cavite
SUPT. NORAINAH BALAGUER, PESE
Imus Police Station
Imus City, Cavite
PO1 ENGELBERT VILLAFRANCA
Imus Police Station,
Imus City, Cavite
12. MOTION TO RENDER JUDGMENT – A motion asking the court to issue

summary judgment on at least one claim. If the motion is granted, a decision is
made on the claims involved without holding a trial. Typically, the motion must
show that no genuine issue of material fact exists, and that the opposing party loses
on that claim even if all its allegations are accepted as true, or that the opposing
party failed to file a responsive pleading.
Complainant,
JASPER SOL CRUZ,
Accused.
x - - - - - - - - - - - - - - - - - - - - - - - - -x
MOTION TO RENDER JUDGMENT
Private Complainant, by counsel, to this Honorable Court respectfully
states:
The above-entitled complaint was filed on 06 May 2011.
Respondent should have filed his Answer on 21 May 2011 yet, to date, upon
verification with the court records, respondent Jasper Sol Cruz has not yet
filed the aforesaid Answer.
Private Complainant prays for the speedy resolution of this case as provided
for by the Revised Rules of Court and in consonance with the timeless legal
maxim that justice delayed is justice denied.
PRAYER
WHEREFORE, premises considered, it is respectfully prayed that a decision
be rendered in the above-entitled case in the interest of justice.
Other reliefs, which are just and equitable, are also prayed for.
City of Manila, for Imus City, 25 May 2011.
PARIL LAW OFFICE
Sampaloc, Manila
by:
JEFFREY PARIL
Copy furnished:
Imus City, Cavite
CLERK OF COURT
Greetings:
In view of the nature of the foregoing motion, the undersigned is requesting
the Clerk of Court to submit the same to the Honorable Court immediately
upon receipt thereof, for its consideration and resolution.
JEFFREY PARIL
Notice:
CLERK OF COURT
Explanation
Copy of the pleading was furnished to the defendant by registered mail due to
the distance of the undersigned from the said parties, making personal service
JEFFREY PARIL
13. MOTION OF REQUEST FOR OFFICIAL COPY – A motion that may be

filed by an interested party or through their counsel to the court or office involved,
in order to request for a certified true copy of a decision, order, resolution, or any
other document issued by the said court or office.
Complainant,
-versus- CRIMINAL CASE NO. 9935-
JASPER SOL CRUZ,
Accused.
x - - - - - - - - - - - - - - - - - - - - - - - - -x
MOTION OF REQUEST FOR OFFICIAL COPY
(OF HONORABLE COURT’S RESOLUTION DATED 23

SEPTEMBER 2010)
Accused, by counsel, to this Honorable Court respectfully states:
Accused was formerly represented xxx by JANSEN ABESAMIS KALAW
OLAGUER LAPUZ LAW FIRM (JAKOL Law).
On 24 August 2011, accused served notice to JAKOL Law of its decision to
cease all legal representation handled by the latter on behalf of the petitioner.
Petitioner also requested JAKOL Law to make arrangements for the transfer
of all files relating to its legal representation on behalf of petitioner to the
undersigned counsel.
The undersigned counsel was engaged to act as counsel for the accused in the
above-entitled case; and thus, filed its entry of appearance on 12 September
2011.
The undersigned counsel, through petitioner, has received information that the
Honorable Court promulgated a Resolution on accused’s Motion for
Reconsideration.
To date, the undersigned counsel has yet to receive an official copy of the
above-mentioned Resolution.
WHEREFORE, undersigned counsel hereby respectfully requests for an
official copy of the Honorable Court’s Resolution on accused’s Motion for
Reconsideration
Imus City, October 19 2011.
by:
Roll No. 690069

IBP No. 990905/ 1-03-2012/Cavite
Notice
CLERK OF COURT
Greetings:
Please submit the foregoing motion for the consideration and
14. MOTION TO RESET HEARING – A motion which may be filed to request

the court to reset the hearing of the instant case to another date, subject to the
availability of the Honorable Court's calendar. Provided, further, that it be made in
good faith and not intended to delay the proceedings of the case
NATIONAL CAPITAL JUDICIAL REGION
METROPOLITAN TRIAL COURT
Branch 59
MANDALUYONG CITY
PEOPLE OF THE PHILIPPINES,

Plaintiff,
- versus - Criminal Case No. 99458
CRISTINA RAVAGO y GALANG,

Accused.
X ------------------------------------------ X
MOTION TO RESET HEARING
COMES NOW the undersigned ACCUSED, unto this Honorable Court respectfully states THAT:
1. Accused was previously represented by Atty. Jimmy D. Lacebal who however later on withdrew his appearance as counsel
for the Accused;

2. Accused desires that she be represented only by a private counsel of her own choice; and Accused has already contacted
one however he will not available on this coming November 25, 2011 (Friday) hearing, and thus undersigned accused most respectfully requests
for a resetting of the hearing FOR THE LAST TIME to December 6 or 13, 2011 (Tuesdays) or on such other dates falling on a Tuesday;
3. That this motion to reset is not intended to delay this case but based on above reasons.
WHERFORE, premises considered, it is most respectfully moves that the November 25, 2011 hearing be reset to either December 6 or
13, 2011.
Mandaluyong City, November 18, 2011.
CRISTINA G. RAVAGO
Accused
NOTICE OF HEARING
The Clerk of Court

Metropolitan Trial Court Branch 59
Mandaluyong City
Greetings:
Kindly submit the foregoing motion for the consideration and approval of the Honorable Court immediately upon your receipt hereof.
CRISTINA G. RAVAGO
EXPLANATION
Undersigned Accused has furnished the private prosecutor a copy of the foregoing motion though registered mail, and not by personal
delivery, because of distance and time constraint.
CRISTINA G. RAVAGO
COPY FURNISHED by registered mail:

Atty. Maria Bote-Veguilla
Private Prosecutor
5th Floor Strata 100 Building
F. Ortigas Jr. Avenue, Ortigas Center, Pasig City, Metro Manila
15. MOTION TO WITHDRAW AS COUNSEL – A motion filed by counsel to

withdraw as such, complying with the requirements under Section 26, Rule 138 of
the Rules of Procedure, and for the reasons stated in Rule 22.01 of Canon 22 of the
Code of Professional Responsibility.
BRANCH 113
Pasay City
Petitioner,
-versus-
For: Declaration of Nullity of
Marriage
ELLEN A. ADARNA,
Respondent
x------------------------------------------x
MOTION TO WITHDRAW AS COUNSEL
COMES NOW the undersigned counsel and to this Honorable Court
respectfully states that:
She is the counsel of record for the petitioner in the above-entitled case.
Diligent efforts were exerted to communicate with the petitioner in relation to
the above-entitled petition, which proved to be unfruitful. Also, there are
some reasons, which are confidential in nature, thus, the undersigned counsel
is constrained to withdraw, as he hereby withdraws his appearance as counsel
for the petitioner whose conformity hereto cannot be obtained despite
previous efforts exerted by the undersigned counsel.
WHEREFORE, it is respectfully prayed that the appearance of the

undersigned counsel for the petitioner be considered withdrawn.
Imus City, for Pasay City, December 24, 2013.
LOMIBAO LAW OFFICE
406 Violago Homes, Litex, Quezon City
Tel. No. 0917- 8032- 788
Email Add.: LLawOffice@yahoo.com
by:
IBP No. 119739 CAVITE CHAPTER
PTR No. 3181314, Imus City, 1-11-12
MCLE Compliance No. VI-1111201
Notice
Pasay City
ELLEN A. ADARNA
Greetings:
Please take notice that in view of the nature of the foregoing Motion,
the undersigned has requested the Clerk of Court to submit the same for the consideration and approval to
the Honorable, immediately upon receipt
hereof.
Copy furnished:
HON. SOLICITOR GENERAL
134 Amorsolo St., Amorsolo Bldg.,
Legaspi Village, Makati City
Pasay City
ELLEN A. ADARNA
Explanation
This motion is being filed, with copy thereof furnished the other party, by
registered mail due to the distance of the undersigned from the Court and said
other party, making personal filing and service thereof not practicable.

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Balunos, Arron

1. MOTION FOR ISSUANCE OF HOLD DEPARTURE ORDER- A

JASPER SOL CRUZ,

MOTION FOR ISSUANCE

Branch 21, Imus City

2. MOTION FOR LEAVE OF COURT TO FILE DEMURRER TO

3.MOTION FOR BILL OF PARTICULARS - A motion which may be filed

Defendant, by counsel and to this Honorable Court, respectfully

4. MOTION FOR CONSOLIDATION OF CASES - A motion requesting the

5. MOTION FOR PERMANENT DISMISSAL- a motion requesting the court to

REPUBLIC OF THE PHILIPPINES,

2nd Floor, RCVJ Building,

6. MOTION FOR CANCELLATION OF LIS PENDENS - A motion filed to

1. Misbehavior of an officer of a court in the performance of his official duties or

2. Disobedience of or resistance to a lawful writ, process, order, or judgment of a

3. Any abuse of or any unlawful interference with the processes or precoeedinfs of

4. Any improper conduct tending, directly or indirectly, to impede, obstruct, or

5. Assuming to be an attorney or an officer of the court, and acting as such without

6. Failure to obey a subpoena duly served;

7. The rescue, or attempted reduce, of a person or property in the custody of an

WHEREFORE, plaintiff prays that after respondent shall have been

8. EX PARTE MOTION TO DISMISS - It is an application for a relief in a legal

OFFICE OF THE CITY PROSECUTOR

9. MOTION TO INHIBIT - It is an application for a relief in a legal proceeding

In view of the foregoing, to avoid the appearance of bias and impropriety, it is

10. MOTION TO LIFT ORDER OF ARREST - It is a motion to lift the order of

ATTY. ALEXANDER LIQUIGAN

11. MOTION TO RELEASE MOTOR VEHICLE – A motion where the police,

Accused, by counsel, to this Honorable Court respectfully states:

Don P. Campa Avenue, Barrio Uno,

12. MOTION TO RENDER JUDGMENT – A motion asking the court to issue

13. MOTION OF REQUEST FOR OFFICIAL COPY – A motion that may be

(OF HONORABLE COURT’S RESOLUTION DATED 23

Roll No. 690069

14. MOTION TO RESET HEARING – A motion which may be filed to request

PEOPLE OF THE PHILIPPINES,

- versus - Criminal Case No. 99458

CRISTINA RAVAGO y GALANG,

MOTION TO RESET HEARING

for the Accused;

Mandaluyong City, November 18, 2011.

The Clerk of Court

delivery, because of distance and time constraint.

COPY FURNISHED by registered mail:

15. MOTION TO WITHDRAW AS COUNSEL – A motion filed by counsel to

WHEREFORE, it is respectfully prayed that the appearance of the

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