REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT

_______ Judicial Region
BRANCH _____,

IN THE MATTER OF THE

PETITION FOR THE EXCLUSION
FROM THE LIST OF VOTERS OF
PRECINCT NO 158B,
BARANGAY SAN NICOLAS,
IRIGA CITY.

___________________,
Petitioner,

Election Case. No. ___________

- versus - For: EXCLUSION OF VOTERS

____________________________,
registered voter of
__________________________
AND THE ELECTION
REGISTRATION BOARD,
____________
Respondent.

x- - - - - - - - - - - - - - - - - - - - - - - - - - - - -x
MOTION TO ADMIT PETITION FOR EXCLUSION
(EX ABUNDANTI AD CAUTELAM)

Petitioner, by himself, unto this Honorable Court, respectfully state

and depose THAT:

1. Petitioner was made aware of the inclusion of the

_________________________e, in the list of voters only on April 12,
2021.

2. Unfortunately, Oppositions to contest a registrant's

application for inclusion in the voter's list must, in all
cases, be filed not later than the second Monday of the
month pursuant to RA 8189, which date is on April 12, 2021.

3. In order to oppose the inclusion of the petitioner, a letter of

opposition was attempted to be filed with the COMELEC but it was
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 not accepted for failure to conform to the required form and the
petitioner despite compliance with the required form was unable to
submit his petition during office hours on April 12, 2021.

10. The failure to challenge the inclusion of voters on the last day as
provided for by law was not the intention of the petitioner but for
lack of knowledge on how to make the necessary challenge on the
inclusion of voters since he is not being a lawyer but merely a
concerned citizen who wants to do the right thing and correct the
list of voters.

11. Hence, this motion.

PRAYER
WHEREFORE, premises considered, it is respectfully prayed of this
Honorable Court that the Petition be ADMITTED by the Honorable Court.

Other just, equitable and proper remedies and relief under the
premises are likewise prayed for.

Iriga City, Philippines, April 13, 2021.

______________________
Petitioner

EXPLANATION AND COPY FURNISH

(Pursuant to Section 11, Rule 13 of the 1997 Rules of Civil

Procedure)

The foregoing Motion to Admit Petition for exclusion Ex Abundanti Ad

Cautelam and the Appellees’ Brief will be filled personally to the
Honorable Court and served to the ERB and the respondent voter, by
registered mail due to the fact that the petitioner is already a senior citizen
and an immunocompromised individual with the danger of being exposed
to the pandemic known as COVID 19.

____________________
Petitioner

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