REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

7th JUDICIAL REGION
BRANCH 53
LAPU-LAPU CITY

CARMENCITA DAGAT FUERTES,

Petitioner,

Civil Case No. R-LLP-14-07005-CV

-versus- For: Declaration of Nullity of Marriage

BAYANI Q. FUERTES,
Respondent.
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MOTION TO CONDUCT HEARING

THROUGH VIDEO CONFERENCING

Petitioner, through counsel, respectfully states:

1. The instant case is scheduled for the presentation of

petitioner’s evidence on 07 October 2021 at 8:30 o’clock in the morning.

2. During the said hearing, the undersigned intends to present

Ms. Maryjun Delgado as petitioner’s first witness, whose testimony will
be offered to prove that:

i. She is a licensed psychologist;

ii. She conducted a psychological examination in relation
to this case;
iii. She recorded the findings of her examination in a
Psychological Assessment Report that she will identify;
iv. Based on her examination, respondent is suffering
from a personality disorder that renders him
psychologically incapacitated to perform his marital
obligations to petitioner;
v. other such matters relevant to the case.

5. The afore-named expert witness is presently residing in

Mandaue City, while the undersigned counsel’s office address is in

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Cebu City. To petitioner’s knowledge, Hon. Pros. Antonio Aseniero is
holding office at the Office of the City Prosecutor of Lapu-Lapu City in
Lapu-Lapu City, Atty. Jesse Mae Cinco Diaz-Durano is holding office in
Cebu City, while the Honorable Court is located in Lapu-Lapu City.

6. The e-mail address of the witness Ms. Maryjun Delgado is

maryjund709@gmail.com, the e-mail address/es of the undersigned
counsel for petitioner are atty_chevrolie@yahoo.com and/or
tggt_law@yahoo.com, the e-mail address of the counsel for the
respondent is jesse12diaz@yahoo.com, and the e-mail address of Hon.
Pros. Antonio Aseniero is ocpllp.aseniero@gmail.com.

7. The witness Ms. Maryjun Delgado and the undersigned are

aware that the fully-remote videoconferencing hearing shall be
conducted using the Microsoft Teams platform, and they manifest that
they are technically ready to participate in the videoconferencing hearing
using such online platform.

8. Pursuant to O.C.A. Circular No. 120-2021 issued on

08 September 2021 encouraging the court to maximize the use of
videoconferencing hearings, and taking into account and health and
safety considerations to prevent the spread of the virus and curb the
Covid-19 pandemic, petitioner hereby prays that the hearing in the
instant case be conducted through fully-remote videoconferencing.

RESPECTFULLY SUBMITTED.

04 October 2021.

Cebu City (for Lapu-Lapu City), Philippines.

TORREGOSA GALEON GRAVADOR & TOMANENG

Counsel for the Petitioner
Suite 210, 2nd Floor, The Walk, Cebu I.T. Park
Lahug, 6000 Cebu City
Telefax No. (032) 233-3578
Email Address: tggt_law@yahoo.com

BY:

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 CHEVROLIE E. MAGLASANG
PTR No. 2022534; 02.02.21; Cebu City
IBP No. 149407; 01.14.21; Cebu
Roll of Attorneys’ No. 57425
MCLE Compliance No. VII-0001453
Issued on 08 November 2019 at Pasig City

Copy Furnished: (via electronic mail)

OFFICE OF THE CITY PROSECUTOR

Hall of Justice
Lapu-Lapu City
ocpllc.aseniero@gmail.com

ATTY. JESSE MAE C. DIAZ-DURANO

Room 202 Aniceta Bldg., Capitol Site
Osmeña Blvd., Cebu City
jesse12diaz@yahoo.com

OFFICE OF THE SOLICITOR GENERAL

134 Amorsolo St., Legaspi Village
Makati City, 1229, Philippines
efile@osg.gov.ph
docket@osg.gov.ph

WRITTEN EXPLANATION

In compliance with Section 11, Rule 13 of the Rules of Court,

counsel explains that the foregoing motion will be served upon the above
addressees by electronic mail due to time constraints and distance, which
make personal service not practicable.

CHEVROLIE E. MAGLASANG

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Republic of the Philippines )
City of Cebu )s.s.
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AFFIDAVIT OF FILING AND SERVICE

I, ATTY. CHEVROLIE E. MAGLASANG, Filipino, of legal age, and

with address at TORREGOSA GALEON GRAVADOR & TOMANENG LAW
OFFICES, Suite 210, Second Floor, The Walk, Cebu I. T. Park, Lahug, Cebu
City, Philippines, after having been duly sworn to in accordance with law,
hereby depose and say:

That on 04 October 2021, I filed electronically and served copy of

the following pleading/paper:

MOTION TO CONDUCT HEARING

THROUGH VIDEO CONFERENCING

in Civil Case No. R-LLP-14-07005-CV titled, “CARMENCITA

DAGAT FUERTES VS. BAYANI Q. FUERTES”, pursuant to the Revised
Rules of Court as follows:

Copy Furnished: (via electronic mail)

OFFICE OF THE CITY PROSECUTOR

Hall of Justice
Lapu-Lapu City
ocpllc.aseniero@gmail.com

ATTY. JESSE MAE C. DIAZ-DURANO

Room 202 Aniceta Bldg., Capitol Site
Osmeña Blvd., Cebu City
jesse12diaz@yahoo.com

OFFICE OF THE SOLICITOR GENERAL

134 Amorsolo St., Legaspi Village
Makati City, 1229, Philippines
efile@osg.gov.ph
docket@osg.gov.ph

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 IN WITNESS WHEREOF, I have hereunto affixed by signature this
04th day of October 2021, at Cebu City, Philippines.

ATTY. CHEVROLIE E. MAGLASANG

Affiant

SUBSCRIBED AND SWORN TO BEFORE ME this 04th day of

October 2021 at Cebu City, Philippines. Affiant exhibited to me her IBP
Membership Card with Roll No. 57425.

DIANA A. VELASCO
NOTARIAL COMMISSION NO. 074-10
NOTARY PUBLIC FOR AND IN THE CITY OF CEBU
UNTIL DECEMBER 2021
TORREGOSA GALEON GRAVADOR & TOMANENG LAW OFFICES
SUITE 210, 2ND FLOOR, THE WALK, CEBU I.T. PARK, LAHUG, CEBU CITY
MCLE COMPLIANCE No. VI-0003684; 10.25.17; PASIG CITY
PTR No. 2022533; 02.02.2021; Cebu City
IBP No. 149406; 01.14.21; Cebu
ROLL OF ATTORNEYS’ No. 57425
TIN 244.203.101.000
Doc No. 271;
Page No. 55;
Book No. 45;
Series of 2021.

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