Republic of the Philippines

Tenth Judicial Region

REGIONAL TRIAL COURT
Branch 35

PEOPLE OF THE PHILIPPINES, Criminal Case No. RTC 8899

Plaintiff, For: ACTS OF LASCIVIOUSNESS
IN RELATION TO R.A.7610
VS.

RICKY M. FLORIN,
Accused.

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REQUEST FOR SUBPOENA DUCES TECUM AD TESTIFICANDUM

WITH MANIFESTATION

COMES NOW, Accused through counsel, most respectfully request for the
issuance of Subpoena Duces Tecum Ad Testificandum to the following witnesses
to testify on matters material to the defense:

NAME/ADDRESS PURPOSE

APOLINAR SACOTE
Mialen, Clarin
Misamis Occidental To testify on the fact that he was the one
who accompanied Vernadeth Verallo on
July 24, 2018; to refute the testimonies of
witnesses, Vernadeth Verallo and Fredelisa
Verallo that Vernadeth went to the Police to
report the incident on July 9, 2018 and to
disprove the testimony of Fredelisa Verallo
that she went to the police station on July
24, 2018 together with Mr. Sacote and
Vernadeth; that Fredelisa coached her
daughter to testify in the manner that she
had testified in court. To prove that the
testimonies of Vernadeth and Fredelisa
pertaining to what the Accused did was not
true and a product of an afterthought.

ALISON SUBRABAS To clarify the testimony of witness Fredelisa

Mialen, Clarin Verallo regarding her Complaint Affidavit
Misamis Occidental marked as Exhibit 1 for the Defense.

1
PO1 JENNALYN MANZANO COMISON To testify on the Certifiation issued
Philippine National Police by the PRO-10 regarding the
Police Regional Office-10 complaint filed by Vernandeth
Ozamis City Police Station Verallo, being the investigator of
the case.

Defense requests that PO1 Jennalyn Manzano Comison be ordered to bring the
records pertaining to the reported incident on July 24, 2018.

The above-named witnesses will serve as substitute witnesses of three witnesses

whose testimonies are collaborative in nature.

Respectfully submitted.

Ozamiz City, 10 May 2021.

RAMAYRAT LEGAL SERVICES

Purok 2, Banadero Highway
Ozamiz City, Misamis Occidental

Atty. Noel A. Ramayrat

Counsel for the Accused
PTR No. 4209861 A Ozamiz City
Roll No. 29884
IBP 002522
MCLE VI 0028505
Tel: 0927-407-5459
Email: noelatty@gmail.com