Republic of the Philippines

Department of Justice
National Prosecution Service
OFFICE OF THE PROVINCIAL PROSECUTOR
Alabel, Sarangani Province
(083) 5082250

ENREQUE B. YAP, JR., NPS DOC. NO. XII-07-INV-

Complainant, 22G – 00333

-versus- -for-

VANNY DOMINGO, ET. AL., Violation of Art. 315 2(a) of RPC as

Respondents, amended by Sec. 85 of RA 10951
x-----------------------------------x

MOTION TO ADMIT

Respondents, through counsel, unto this Honorable Office of

the Provincial Prosecutor, respectfully submits this Motion and states
THAT:

1. Respondents, as well as their witnesses, subscribed and

submitted, respectively, their Counter Affidavits and Affidavits before
this Honorable Office on August 11, 2022;

2. However, two (2) witnesses were not able to appear

during that day because they were still onboard on their fishing boats
and the was no means to communicate with them;

3. In the interest of justice, we intend to belatedly submit

their affidavits attached herein to corroborate our defenses.

WHEREFORE, premises considered, it is respectfully prayed for

that this Honorable Office of the Provincial Prosecutor considers the
belated submission and the affidavits of witness KEKEN BALURAN
and EDUARDO BALLOS, SR. be admitted.

Other reliefs just and equitable under the premises are likewise
prayed for.

Motion to Admit 1 | 2
 General Santos City for the Alabel, Sarangani Province, 18
August 2022.

RESPECFULLY SUBMITTED.

CLEMENTE A. PANGANDUYON
Counsel for Respondents
Roll No. 72479/14June2019/Manila
MCLE Compliance No.: VII-0014243
IBP No.: 183475/ 03 JAN 2022
PTR No. 0032295/ 03 JAN 2022

3rd Floor, C. CZAR & Co. Building (Beside

EastwestBank), Santiago Blvd,
9500 General Santos City
clementepanganduyon@gmail.com
(0915) 356 0224

Copy furnished:

ENREQUE B. YAP
Barangay Poblacion,
Glan, Sarangani Province

Motion to Admit 2 | 2