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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


NATIONAL CAPITAL JUDICIAL REGION
MALABON CITY
BRANCH 289

KHENNY GO KHU,
Petitioner,

-versus- Civil Case No. 2476-MAL


For: Declaration of Nullity
of Marriage

JANNETTE L. KHU,
Respondent.
X------------------X

MOTION TO DECLARE FINALITY

Comes now the petitioner, thru the undersigned counsel and


unto this Honorable Court most respectfully states:

1. On February 14, 2022, the petitioner counsel received an


email from the court with the attached Order dated
February 8, 2022, resolving the Motion to Seek Update on
This Case” filed by the counsel of the Petitioner.

2. In the Order, before the issuance of the Certificate of


Finality, this Honorable Court directed the counsel for the
petitioner to submit proof of receipt by the Office of the
Solicitor General of the Resolution dated March 4, 2021,
within ten (10) days from receipt of this Order.

3. In compliance with the Order, we are submitting digital


picture of the Certification issued by Office of the Solicitor
General (OSG) acknowledging receipt of the Order dated
March 4, 2021 on April 16, 2021. Copy of the Certification
dated February 18, 2022 is attached herein for your
reference.

4. In view thereof, considering several months have lapsed


since the denial of the Motion for Reconsideration filed by
the Office of the Solicitor General, it is but proper for this
Honorable Court to issue a Certificate of Finality of the
Decision in this case.
5. This Motion is filed not to delay the proceedings of this case
but mainly for the reasons above-stated.

PRAYER

WHEREFORE, premises considered, it is most respectfully


prayed that the Certificate of Finality of the Decision in this case be
issued and the appropriate entry on the court docket be made on
said finality.

Other reliefs as are just and equitable under the


circumstances are likewise prayed for.

18 February 2021, Pasay City for Malabon City.

RESPECTFULLY SUBMITTED

Atty. RAYSUN R. ARELLANO


Counsel for the Petitioner
8th Floor, IMET BPO, Metropolitan Park
Bay Area, Roxas Boulevard, Pasay City
IBP No. 130516/10/14/2020 (paid in advance)
PTR No. 0199951 01/27/2022/Manila
MCLE Compliance IV 000577/09/29/2016
Roll No. 66646
Mobile No. 09452245337
Email Add: attyraysunarellano@gmail.com

NOTICE OF HEARING

The Branch Clerk of Court


RTC Branch 289
Malabon City

Please submit the foregoing Motion for the kind consideration


of this Honorable Court at the soonest time that its calendar is
available.

Copy Furnished:

Office of the Solicitor General docket@osg.gov.ph


143 Amorsolo St., Legaspi Village
Makati City, 1229
Office of the City Prosecutor ___________
Malabon City

EXPLANATION

Pursuant to Supreme Court Administrative Circular No. 41-


2020 dated 29 May 2020, a copy of this Motion was electronically
sent to the parties to their official email address mail and by
registered mail due to the effects of the ongoing Covid-19
pandemic.

RAYSUN C. ARELLANO

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