Republic of the Philippines

REGIONAL TRIAL COURT

7th Judicial Region
Branch 6-FC
Mandaue City

EDNA A. PILAPIL-PRESBITERO,
Petitioner,

-versus - CIVIL CASE NO. MAN-8545

FOR: Declaration of Nullity of
Marriage
JUANITO P. PRESBITERO,
Respondent.
X-------------------------/

MOTION TO INVESTIGATE COLLUSION

and
NOTICE OF CHANGE OF ADDRESS

COMES NOW, Petitioner, through the undersigned Counsel, unto

this Honorable Court, most respectfully states that:

1. On April 21, 2021, the Sheriff filed its Return stating that Summons was
served on Respondent on April 16, 2021 and personally received by
him, as evidenced by the signature of respondent appearing on the
Original Summons.

2. To date, Petitioner had not received a copy of Respondent’s Answer

to the petition.

3. Under Section 8, paragraph (3) of A.M. No. 02-11-10-SC, the Court shall
order the public prosecutor to investigate whether collusion exists
between the parties when there is no answer filed.

4. The Honorable Court issued an Order, dated June 21, 2021 directing
the Office of the Provincial Prosecutor to investigate whether
collusion exists between the parties, and to include in the report a
determination of the Petitioner’s residence.

5. Petitioner had not received any report from the Office of the
Provincial Prosecutor on whether the parties are in collusion up to this
time.
 6. Petitioner can be reached by the Office of the Provincial Prosecutor
through her mobile number 09459673836 and e-mail address:
pilapiledna58@gmail.com. She can also be reach on her facebook
account: Edna Presbitero. Her exact address is Purok Mangga, Brgy.
Tayud, Liloan, Cebu, Philippines.

7. In accordance with the above-quoted rule, we humbly request from

this Honorable Court to issue an appropriate order for the Public
Prosecutor to conduct investigation whether the parties are in
collusion.

8. The undersigned Counsel hereby makes of record her change of office

address. It is most respectfully requested that, the undersigned be
furnished with copies of all orders, resolutions, notices and other
pleadings at:

ATTY. CONCEPCION T. CEJANO

Cabalilitan, Tabunan, Borbon
Cebu, Philippines.

WHEREFORE, Petitioner respectfully prays that this Honorable

Court issue the appropriate order for the Public Prosecutor to investigate
whether collusion exists between the parties, and to take notice of the
undersigned Counsel’s change of address.

RESPECTFULLY SUBMITTED.

Borbon, Cebu for Mandaue City, October 18, 2021.

CONCEPCION T. CEJANO
Counsel for Petitioner
Cabalilitan, Tabunan, Borbon, Cebu
Roll of Attorneys No. 70455
IBP No. AR36828951; 01/04/21, Cebu
PTR No.2243087; 01/05/21, Cebu City
MCLE Compliance No. VI-0016216
Valid until April 14, 2022

NOTICE OF SUBMISSION
(With Copy Furnished)

Branch Clerk of Court

RTC-Brach 6-FC
Mandaue Hall of Justice
Mandaue City
 Greetings: Please take notice that the foregoing MOTION and NOTICE OF
CHANGE OF ADDRESS, shall be submitted for the kind consideration and
approval of the Honorable Court.

CONCEPCION T. CEJANO

COPY FURNISHED:

Office of the Solicitor General

134 Amorsolo St., Legaspi Village
Makati City

Office of the Provincial Prosecutor

Cebu Provincial Office
2nd Floor, DOJ Cebu building
D.A. Compound, M. Velez St.,
Cebu City

Juanito P. Presbitero
Sitio Dolinson, Poblacion,
Borbon, Cebu

The service of this Motion and Notice of Change of Address to the

Honorable Court, Office of the Solicitor General, the Office of the Provincial
Prosecutor, and the Opposing Party were made by registered mail due to
distance, and lack of personnel to effect personal service.

CONCEPCION T. CEJANO