Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

Second Judicial Region
Branch 03
Tuguegarao City, Cagayan

PEOPLE OF THE PHILIPPINES,

Plaintiff,
CRIMINAL CASE NO.: 32478
-versus- -for-
ESTAFA
NELIA BORGA SIMON, ET. AL.,
Accused.

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MANIFESTATION WITH MOTION

The undersigned counsel, most respectfully submits the

following Manifestation with Motion for the Honorable Court’s
consideration and approval, and state:
1. That the undersigned counsel was set to appear before the
Honorable Court last 29 November 2022 at 8:30 in the morning for
the continuation of Defense’s evidence;

2. However, the undersigned counsel inadvertently placed the

scheduled hearing at 1:30 in the afternoon of the same date;

3. Likewise, the undersigned counsel failed to locate and contact

their last intended witness for the said trial date as he allegedly
moved in a different province;

4. That the undersigned counsel intended to rest her case had it not
been for the mixed schedule.

PRAYER

It is therefore respectfully prayed of this Honorable Court that:

1. The scheduled hearing on 1 February 2023 at 8:30 in the

morning be waived;

2. The Defense be allowed to submit their Written Formal Offer of

Evidence;

1
 3. Other equitable relief and remedies as may be deemed just and
equitable are likewise prayed for.

Respectfully submitted, Tuguegarao City, Cagayan. 2 December

2022.

GLAESAN G. ADRIANO
Counsel for the Accused
SALES, ADRIANO, AMAN-CRISTOBAL, NATIVIDAD
Law Offices
2 Floor Marivic Auto Supply Building, Diversion Road,
nd

Tuguegarao City, Cagayan 3500

IBP Roll #: 77326 – May 7, 2022
PTR OR #: 3103139 – Tug. City; 05/11/2022
IBP OR #: 207515 – 05/07/2022
MCLE (Newly admitted to the Bar 5/7/22)
CP #: (+63) 919-094-7483
saanlawoffice@gmail.com

Copy furnished through personal service to:

PROS. FRANCIELLE PURUGGANAN-AGUILA

City Prosecutors Office
Tuguegarao City, Cagayan