REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURTOF NEGROS ORIENTAL

Seventh Judicial Region
BRANCH 43
Tanjay City
Stationed at San Jose

RAINELDA A. SALVA, ET. AL., CIVIL CASE NO. 335

Plaintiffs,
FOR: PARTITION,
---versus--- ACCOUNTING AND DAMAGES
WITH DECLARATION OF
FRANCISCO SALVA ET. AL., PRESUMPTION OF DEATH
Defendants.
X-------------------------------------------/

MOTION
[For Issuance of Certificate of Finality]

PLAINTIFFS HEIRS OF NATIVIDAD SALVA MOSA, through

counsels, to this Honorable Court, most respectfully state that:

The Supreme Court had issued a Resolution dated August 23, 2022
denying the Petition for Review filed by Petitioners therein. A copy of the
said Notice/Resolution is hereto appended as Annex “A”.

Considering that no Motion for Reconsideration was filed by

Petitioners, and that the time allowed for the filing of such had already
lapsed, the Decision of the Honorable Court dated 14 March 2016 has
become final and executory.

In view of the foregoing, Plaintiffs pray that a Certificate of Finality

be issued on the Decision dated 14 March 2016.

PRAYER

WHEREFORE, premises considered, Plaintiffs respectfully pray that

the Honorable Court issue a Certificate of Finality on the Decision dated 14
March 2016.
 Other reliefs that are just and equitable are likewise prayed for.

RESPECTFULLY SUBMITTED.

October 26, 2023, in Dumaguete City, Philippines.

MERCADO & PARTNERS LAW FIRM

[For the Plaintiff Heirs of Natividad Salva and Gonzalo Moso]
Suite 1, 2ND Floor, RM Building
North National Highway cor. East Rovira Road
Dumaguete City
Telephone Number 225-5079/422-7253
rmlawfirm@gmail.com/rjam@mercado-partnerslaw.com

by:

ATTY. RAYMUND J. A. MERCADO

PTR NO. 3494367A-01/03/2023
IBP LIFETIME NO. 01108
All Issued in Dumaguete City, Philippines
7th MCLE Compliance No. 23282 (08/31/22)
Roll No. 35548/ 4-28-1989

and

ATTY. MARVILIE M. SERNA

PTR NO. 3494373A-01/03/2023
IBP NO. 279997-01/10/2023
All Issued in Dumaguete City, Philippines
MCLE Compliance No. VII-0019483
Roll No. 70642 (06/04/18)
 REQUEST FOR SUBMISSION/
NOTICE OF HEARING

The Clerk of Court

REGIONAL TRIAL COURT OF NEGROS ORIENTAL
BRANCH 43
Tanjay City
Stationed in San Jose

Greetings:

Kindly submit the foregoing Motion for the approval of the

Honorable Court immediately upon your receipt hereof, with or without
further arguments.

Should a hearing be called for, the suggested date of hearing is on

October 20, 2023 or on any date convenient to the Honorable Court.

Thank you.

MARVILIE M. SERNA

Copy furnished:

ATTY. EDUARDO SEDILLO

Dumaguete City

ATTY. EDDIE ABA

Capitol Area, Dumaguete City