Republic of the Philippines

REGIONAL TRIAL COURT

First Judicial Region
Branch ____
Baguio City

ANA MARI L. EVANGELISTA,

Petitioner,

CIVIL CASE No. 1368 – FC

- versus - For: Declaration of
Nullity of Bigamous
Marriage
LAURO DE LEON GATAPIA,
Respondent.
x-------------------------------------------x

MOTION

PETITIONER, through counsel, unto this Honorable Court,

respectfully avers that:

1) The respondent’s current address is in 87-B Pag-asa Street,

Taytay, Rizal, as mentioned in the Petition;

2) The respondent has a history of evading service of court

processes;

3) It has come to the attention of the petitioner that the

respondent might leave the country soon;

4) Although the address of the respondent is beyond the

jurisdiction of this court, the petitioner believes that personal
service would be better considering the foregoing;

5) A relative of the petitioner will accompany the sheriff of this

court to guarantee the personal service of summons on the person
of the respondent.

WHEREFORE, premises considered, it is respectfully prayed that

the sheriff of this court be deputized to personally serve upon the person
of the respondent summons and other court processes in relation to this
case.

In the City of Baguio, Philippines, this ____ day of June 2014.

 A B S LAW OFFICES
Suite 305, Laperal Building
Session Road, Baguio City
Tel No. (074) 442-8243

By:

PATRICIA MARIE FRANCES DE PERALTA CASTRO

PTR No. 1731263/05.09.2014/Baguio City
IBP Lifetime No. 968452/04.04.2014/Baguio City
Roll No. 63622
MCLE Governing Board, Order No. I. s. 2008, 04 July 2008

NOTICE

OFFICE of the CITY PROSECUTOR

Justice Hall, Baguio City

Greetings:

Please take notice that the foregoing Motion will be submitted for
the resolution of the Honorable Court immediately upon receipt hereof,
sans appearance.

PATRICIA MARIE FRANCES D. CASTRO

OFFICE of the SOLICITOR GENERAL

134 Amorsolo Street, Legaspi Village
1229 Makati City

Greetings:

Please take notice that the foregoing Motion will be submitted for
the resolution of the Honorable Court immediately upon receipt hereof,
sans appearance.
 PATRICIA MARIE FRANCES D. CASTRO

The BRANCH CLERK OF COURT

RTC – Branch 59
Baguio City

Greetings:

Please submit the foregoing Motion for the consideration and

approval of the Honorable Court immediately upon receipt hereof, sans
appearance.

PATRICIA MARIE FRANCES D. CASTRO

Copy furnished:

OFFICE of the CITY PROSECUTOR

Justice Hall, Baguio City

OFFICE of the SOLICITOR GENERAL (by registered mail)

134 Amorsolo Street, Legaspi Village
1229 Makati City

EXPLANATION

Service of the foregoing Motion to the Office of the Solicitor

General was effected through registered mail with return card due to
distance constraints and lack of manpower to effect personal service.

PATRICIA MARIE FRANCES D. CASTRO