Republic of the Philippines

MUNICIPAL CIRCUIT TRIAL COURT

Lamut-Kiangan-Tinoc-Asipulo
Lamut, Ifugao

HEIRS OF CARLOS M. CHUG-E, CIVIL CASE NO. 709

REPRESENTED BY JANICE D. CHUG-E
Plaintiff,
FOR:
RECOVERY OF POSSESSION
-versus- AND DAMAGES WITH PRAYER
FOR PRELIMINARY INJUNCTION
AND/OR TEMPORARY
RESTRAINING
ORDER
MR. BEN GUMAN
Defendant.
X-------------------------------x

MOTION TO WITHDRAW FORMAL OFFER OF EVIDENCE

(WITH MANIFESTATION)

Plaintiff, through the undersigned counsel, unto this Honorable

Court most respectfully states that:

1. Plaintiff submitted to the Honorable Court her Formal Offer of

Evidence on September 9, 2019 after presenting two (2) witnesses
ex-parte;

2. On September 16, 2019, the Honorable Court issued an Order

partially granting the defendant’s Motion for Reconsideration and
setting the case for Pre – Trial Conference. Further, the Court
deferred the Plaintiff’s Formal Offer of Evidence until after the Pre
– Trial Conference should the plaintiff present additional evidence;

3. In view of the foregoing reasons, the undersigned counsel

respectfully requests that the Plaintiff’s Formal Offer of Evidence
be withdrawn from the records of the case;

4. Further, as part of the Pre – Trial Brief of the Plaintiff in reserving

the right to present additional witnesses, the plaintiff respectfully
manifests that she may be allowed to present one (1) additional
witness.
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 PRAYER

WHEREFORE, it is most respectfully prayed that the Plaintiff’s Formal

Offer of Evidence be withdrawn and that plaintiff be allowed to present one (1)
additional witness.

Plaintiff prays for other reliefs that are just and equitable under the premises.

Done this 19th day of June 2020 at Lagawe for Lamut, Ifugao.

NAMINGIT LAW OFFICE

nd
2 Floor, Alfredoracion Buidling
Pob. East, Lagawe, Ifugao

By:

ATTY. PRESLEY JOHN L. NAMINGIT

Counsel for Plaintiff
Roll No. 69260 – May 31, 2017
IBP No. 1065447 – Dec. 4, 2019
PTR No. 9601763 – Jan. 3, 2020
MCLE Compliance No. VI-0013828 – Oct. 1, 2018

NOTICE

The Clerk of Court

Municipal Circuit Trial Court
Lamut-Kiangan-Tinoc-Asipulo
Lamut, Ifugao

Atty. Placido K. Wachayna, Jr.

Counsel for the Defendant
Poblacion, Banaue, Ifugao

Greetings!

Please take notice that the foregoing Motion to Withdraw Formal Offer of
Evidence with Manifestation shall be submitted for the consideration and approval
of the Honorable Court on June 22, 2020 at 8:30 o’clock or as soon as counsel and
matter may be heard.

Thank you.
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 PRESLEY JOHN L.
NAMINGIT

Copy Furnished:

ATTY. PLACIDO K. WACHAYNA, JR

Counsel for the Defendant
Poblacion, Banaue, Ifugao

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