REPUBLIC OF THE PHILPIPPINES

Regional Trial Court

9th Judicial Region
Branch 22
Pagadian City
-o-

ANNA LYNN G. RAMOS Civil Case No. 5445-2K19

Petitioner, For: Declaration of Nullity
of Marriage
- versus -
(Article 36 of the Family Code)
ROMUEL J. RAMOS
Respondent.
x------------------------------------------- x

URGENT MOTION
FOR EARLIER SETTING

Petitioner, through the undersigned counsel, unto this Honorable Court,

most respectfully states, THAT:

1. The Honorable Court set the continuation of trial of the above-

captioned case on 05 December 2022 at 8:30 in the morning to 5:00 o’clock
in the afternoon;

2. However, the Honorable Presiding Judge was on leave;

3. The undersigned intended, with prior permission from the Honorable

Court, to recall the Petitioner to the witness stand on the said date for purposes
of identifying indispensable documentary pieces of evidence which were
inadvertently omitted when she was previously presented to testify in court;

4. Unfortunately, Petitioner, an overseas Filipino worker (OFW) who is

employed as a nurse in a hospital in Saudi Arabia, could no longer attend on
the next schedule of hearing because she has to go back to Saudi Arabia;

5. She was only granted vacation leave by the said hospital until the end
of December 2022, and her flight back to Saudi Arabia is already scheduled
on 02 January 2023 necessitating her to go to Manila one week before;

6. Moreover, Petitioner was not allowed to extend her leave from work
nor could she secure a leave for the year 2023. She is also not yet certain as to
when she will be granted a vacation leave for the year 2024;

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7. Thus, Petitioner is constrained to ask for this Honorable Court’s
consideration and indulgence to set the continuation of trial within the month
of December 2022 for the petitioner to be able to appear personally in court
and identify the said indispensable documentary pieces of evidence;

8. Finally, this motion is filed in good faith and is never intended to delay
the proceedings of the above-entitled case.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed that

the continuation of trial be set within the month of December 2022 for the
petitioner to be able to appear personally in court and identify indispensable
documentary pieces of evidence inadvertently omitted.

Respectfully submitted, this 5th day of December 2022 at Pagadian City,

Philippines.

ATTY. JOAN SZANNE S. PULMONES

Counsel for the Petitioner
BWP Pawnshop, FS Pajares Avenue, Pagadian City
Cellphone No. 09171780401
Roll of Attorney’s No. 70739
IBP No. 168548 / 12-27-2021
PTR No. 3589467 / 12-27-2021
MCLE Compliance No. VII – 0016774

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 NOTICE

HON. CLERK OF COURT

REGIONAL TRIAL COURT
Branch 22
Pagadian City

GREETINGS:

Please submit the foregoing MOTION for the kind consideration and
resolution of this Honorable Court immediately upon receipt hereof sans
argument and presence of counsel.

ATTY. JOAN SZANNE S. PULMONES

Copy furnished by registered mail due to distance:

THE SOLICITOR GENERAL Registry Receipt No.:__________

134 Amorsolo Street, Date: ___________
Legaspi Village
1200 Makati, Metro Manila

Copy furnished through personal service:

OFFICE OF THE CITY PROSECUTOR Received by: ____________

Hall of Justice Date: ____________
Pagadian City

ROMUEL J. RAMOS Received by: ____________

EDMARS Enterprises Date: ____________
Pagadian City

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