REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
URDANETA CITY, PANGASINAN

MARIANO P. FLORES,
Complainant,

-versus-

CANEDIDO C. BALTAZAR,
AND ELPIDIO L. ANDRADA,
Respondents.
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MOTION TO ADMIT
ADDITIONAL EVIDENCES

Complainant Mariano P. Flores, by himself, and unto this

Honorable Court, most respectfully avers:

1. That on September 14, 2020, the above-entitled case was

filed through LBC;

2. That after carefully reviewing the aforementioned complaint,

herein complainant discovered that the certification to file
action1, and Judicial Affidavits executed by Trinidad
Fontanilla2 and Fedencia Andrada 3 were not attached in the
said complaint through mere inadvertence and herein
complainant wishes to include as part of his evidences;

3. That the above-mentioned documentary evidences will prove

that the complainant and his predecessors-in-interest
continuously occupied and cultivated the subject property of
the respondents’ Joint Affidavit In Support of Free Patent
Application and said lot is not free from conflicts and claims
contrary to herein respondents contentions on the said
affidavit;
4. That the complainant now seeks the benevolence of this
Honorable Office to allow the submission of the above-
1 ANNEX “A”.

2 ANNEX “B”.

3 ANNEX “C”.

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 mentioned documents as my additional evidences for the
higher interest of justice;

5. That herein complainant humbly submits that this motion is

made in good faith, and that there was no intent to delay on
his part.

WHEREFORE, premises considered, complainant Mariano P.

Flores respectfully prays that this Honorable Court allow the
submission of his additional evidences.

Other relief and remedies, just and equitable under the

premises and law are likewise prayed for.

City of Manila for Urdaneta City, Pangasinan, 28 October 2020.

EXPLANATION

The complainant respectfully manifests that filing and service

was done by LBC, personal service not being practicable due to
distance constraint.

MARIANO P. FLORES

Copy furnished:

CANEDIDO BALTAZAR
Zone 1 Brgy. Labit Proper,
Urdaneta City, Pangasinan

ELPIDIO ANDRADA
Zone 3 Brgy. Labit Proper,
Urdaneta City, Pangasinan

CERTIFICATION

SUBSCRIBED AND SWORN to before me this ___ day of October

2020, in City of Manila for Urdaneta City, Pangasinan. I hereby certify
that I have personally examined the herein Complainant-Affiant and I
am satisfied and convinced that he read and understood the contents
of his Motion To Admit Additional Evidences and that he executed the
same freely and voluntarily.

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