REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT OF ZAMBOANGA CITY

Ninth Judicial Region
Branch 12

Sps. Francisco M. Tuazon and Linda Civil Case no: 6691

B. Tuazon
Plaintiffs,
Vs for

CITY OF ZAMBOANGA AND OUR RECOVERY OF POSSESSION

BLESSED MOTHER OF VICTORY
MISSION FOUNDATION, INC.
Defendants.

URGENT EX-PARTE MOTION FOR ISSUANCE OF SUBPOENA

AD TESTIFICANDUM

COMES NOW Defendant OUR BLESSED MOTHER OF VICTORY

MISSION FOUNDATION, INC. (OBMVM, for brevity) and for its Urgent Ex-Parte
Motion for ISSUANCE OF SUBPOENA AD TESTIFICANDUM, respectfully states
as follows:
1. The dates set for the hearing of this case are on 23 and 24 October
2017;

2. The Defendant intends to present the following witnesses:

2.1 EFIGENIO JULIAN JR.

Punong Barangay
Brgy. Pasonanca, Zamboanga City

2.2 SHERWIN REY Q. MONTEJO

Real Estate Appraiser

Philippine National Bank – Zamboanga Credit
Investigation and Appraisal Unit
2/F PNB Zamboanga Branch, J.S Alano Street, Zone IV,
Zamboanga City

3. Defendant is compelled to apply for this issuance for the following

grounds:

3.1 Defendant’s witness, the Barangay Captain of Pasonanca,

Zamboanga City, EFIGENIO JULIAN JR. is too busy with
the Barangay’s affairs to come to the law office to execute
his Judicial Affidavit and, witness is also attending to the
needs of the residents who were affected by the flood;

3.2 SHERWIN REY Q. MONTEJO cannot leave behind the

work he is having to execute his Judicial Affidavit and often

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 conducts field works. Hence, acquiring his testimony for the
Judicial Affidavit is rendered futile.

PRAYER

WHEREFORE, OBMVM most respectfully prays that its URGENT

EX-PARTE MOTION FOR ISSUANCE OF SUBPOENA AD
TESTIFICANDUM be GRANTED.

18 October 2017, Zamboanga City, Philippines.

NOTICE OF HEARING

Counsel for Plaintiffs

JOHN PAUL S. PAGTEILAN
2ND Flr, LRC Bldg. Nunez Street,
Zamboanga City

ATTY. JESUS C. CARBON, JR.

Counsel for defendant –
CITY GOVERNMENT OF ZAMBOANGA

Greetings:

Please take note that the undersigned counsel is submitting the foregoing
Motion immediately upon filing without further argument, for the consideration
and approval of this Honorable Court.

18 October 2017, Zamboanga City, Philippines.

ATTY. LINDA EUSTAQUIO-LIM

Copy furnished:

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Counsel for Plaintiffs
JOHN PAUL S. PAGTEILAN
2ND Flr, LRC Bldg. Nunez Street,
Zamboanga City

ATTY. JESUS C. CARBON, JR.

Counsel for defendant –
CITY GOVERNMENT OF ZAMBOANGA
OFFICE OF THE CITY LEGAL OFFICER
Zamboanga City Hall
Zamboanga City

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