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Regional Trial Court of Misamis Oriental: Motion For Reconsideration

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Republic of the Philippines

REGIONAL TRIAL COURT OF MISAMIS ORIENTAL


10th Judicial Region
Branch 37
Cagayan de Oro City

ROSSANA L. NANALE-NAIN R-CDO-19-01142-CV


Petitioner,

For:
- versus - DECLARATION OF NULLITY OF
MARRIAGE

SERGIO V. NAIN
Defendant,
x ------------------------------/

MOTION FOR RECONSIDERATION

THE PETITIONER, by the undersigned counsel, to the Honorable Court, most


respectfully avers that:

1. An Order from this Honorable Court dismissing the instant petition on


the ground that it failed to comply substantially with the Supreme Court
En Banc Resolution dated October 2, 2018, in relation to Section 5 of
A.M
no. 02-11-10-SC was received by the undersigned on July 4, 2019.

2. When the instant petition was filed, the Office of the Solicitor General
was duly served as evidenced by registry receipt no. RE 033 701 40322.
Due to inadvertence however, the Office of the Provincial Prosecutor of
Misamis Oriental, was not served a copy of the same petition;

3. The undersigned has no intention to defy the rules as set forth under
A.M
no. 02-11-10-SC, and for such, a copy of the instant Petition was already
duly served with the office of the Provincial Prosecutor. Proof of which
is hereto attached as ANNEX “A” to “A-2.”

4. Moreso, a certification to the effect that the undersigned counsel has


Motion For Reconsideration
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verified the petitioner’s residency, is hereto attached as ANNEX “B.”

5. The undersigned begs before this Honorable Court for the liberal
construction of the Rules in order to   promote their objectives of
ensuring the just, speedy and inexpensive disposition of every action
and proceeding;

6. In view of the foregoing, the undersigned further begs for the


indulgence of this Honorable Court to reverse and reconsider the Order
dated July 2, 2019, dismissing the instant petition.

WHEREFORE, premises considered, it is most respectfully prayed that the


herein motion be granted.

PALASAN, GALEON, ECLEVIA and ASSOCIATES LAW OFFICE


Door 1, Goodwill Bldg., Rizal – Fernandez Sts., Cagayan de Oro City
palasanlawoffice@yahoo.com/ Contact Nos. (088) 851-2051/0906-509-4613

By:

TIBURCIO M. PALASAN, JR.


ROLL NO. 37410
PTR NO: 4092142, 01-04-2019
IBP NO: 062651, 01-04-2019
Issued in Cagayan de Oro City
MCLE Compliance No.VI-0003957
Issued on November 3, 2017
tmpjr70@gmail.com

NOTICE OF HEARNG

THE CLERK OF COURT


Branch 37
Cagayan de Oro City

Greetings!

Please take notice that the undersigned counsel is submitting the instant
motion immediately upon receipt hereof and kindly set the hearing on July 12
2019, at 8:30 in the morning.

Motion For Reconsideration


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TIBURCIO M. PALASAN, JR.
COPY FURNISHED:

Office of the Provincial Prosecutor (Registered mail due to distance)


City Hall- Cagayan de Oro City Office of the Solicitor General
143 Amorsolo St., Legaspi
Village,
Makati City

Received by: ___________ Registry Receipt __

Motion For Reconsideration


Page 3 of 3

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