REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
BRANCH 48, MANILA

ZHAN, LISHUANG,
Petitioner,

- versus - Civil Case # R-MLA-19-01095-CV

FOR: DECLARATION OF
ABSOLUTE
NULLITY OF
MARRIAGE
XU LIANHUA, OFFICE OF THE SOLICITOR
GENERAL [“OSG”], PHILIPPINE STATISTICS
AUTHORITY & ALL OTHER PERSONS,
Respondents.
X-------------------------X

URGENT MOTION FOR

VIDEO-CONFERENCE HEARING

PETITIONER, by counsel, to this Honorable Court, respectfully moves for

video-conference hearing [including pre-trial conference - 16 December 2020] and avers:
th

Since Petitioner Is Still Stranded In China And

Cannot Personally Attend The Pre-Trial, She
Respectfully Moves For Video Conference Hearing.

[1]THAT recently, petitioner informed the undersigned counsel that she cannot
yet return to the country due to travel restrictions and health and safety of her
children. Thus, there is impossibility on her part to be personally present at the
pre-trial conference, which was set on 16th December 2020.

[2] THAT accordingly, petitioner most respectfully moves for a video-conference

hearing pursuant to the latest OCA Circular No. 161-2020 [dated 24 September 2020]
th

giving authority to all first and second level courts to conduct video conference
hearing regardless of the stage of the proceedings.

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[continuation - Zhan v. Xu
absolute nullity of marriage]
- page 2 -
 THAT similarly, the Honorable Supreme Court also issued Circular No. 39-
[3]
2020 [dated 14 May 2020 - see Section 17] authorizing the conduct of video-conference
th

hearing even to civil cases, that:

“ALL courts initially authorized to hear through videoconferencing only urgent

matters in criminal cases involving Persons Deprived of Liberty are now herein
authorized to hear through videoconferencing ALL matters pending before
them, in both criminal and civil cases, whether newly-filed or pending, and regardless
of the stage of trial.

The videoconferencing hearings in both criminal and civil cases shall be upon joint
motion of the parties, or upon orders of the court, which shall schedule the said
videoconferencing hearings.

xxx xxx xxx.”

THAT consequently, for this purpose, petitioner may be reached through her
[4]
e-mail address zhanlishuang88@icloud.com while her cellphone number is
0096-13600759266 and address is Room 2002, E2 Building, Phase I, Shimao
Skyscraper, Shishi City, Quanzhou City, Fujian Province, ChinaPostal Code ：
362700.

[5] THAT incidentally, undersigned counsel will personally attend the scheduled
pre-trial conference.

THAT this pleading is not for delay, but due to the foregoing urgency and
[6]
necessity.

PRAYER

WHEREFORE, PREMISES CONSIDERED, it is respectfully prayed of this

Honorable Court that the Urgent Motion for Video Conference Hearing BE
GRANTED and notice of pre-trial BE SENT electronically to the petitioner
through zhanlishuang88@icloud.com.

Other equitable reliefs are likewise prayed for.

Manila, 07th December 2020.

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[continuation - Zhan v. Xu
absolute nullity of marriage]
- page 3 -

MERU LLANTINO & DIAZ-SALCEDO

LAW FIRM
Counsel for Petitioner
Unit 209 Intramuros, Corporate Plaza
 Recoletos St., Intramuros, Manila
Telephone Nos. 579-6336/533-8602

By:

MIGUELITO NAZARENO V. LLANTINO

Roll No. 38240
IBP Lifetime Member No. 013830
per O.R. No. 1004190 - 05th May 2015
PTR No. 9120386-Manila-01/02/20
MCLE Compliance VI No. 0027764
issued on 12th July 2019
Cell No. 0999-9990009
miguel999nvl@gmail.com

NOTICE OF HEARING

The Branch Clerk of Court

Regional Trial Court
Branch 48, Manila

Greetings: Please submit this Urgent Motion for Video Conference Hearing
for the kind approval of this Honorable Court immediately upon receipt hereof
or on 11th December 2020 at 8:30 am.

MIGUELITO NAZARENO V. LLANTINO

EXPLANATION : Due to far distance, lack of familiarity. Office of the City Prosecutor
and inadequate staff, a copy of this pleading was Second Floor, LRT Wing
was served by registered mail to the respondent: City Hall, Manila

Xu Lianhua
34D Oxford Parksuites Condo.
G. Masangkay St. corner La Torre St.
Tondo, Manila