Republic of the Philippines

THIRD JUDICIAL REGION

Municipal Trial Court
General Tinio, Nueva Ecija

EVANGELINA M. ABESAMIS,
Plaintiff,

CIVIL CASE NO. 1059

-versus-
FOR: RECOVERY OF POSSESSION
WITH DAMAGES

EMMANUEL ABESAMIS and all other

persons acting in his behalf,

Defendants.
x----------------------------------------------------x
MOTION FOR PRODUCTION OF DOCUMENTS

DEFENDANT, through the undersigned counsel, unto this Honorable Court,

most respectfully states that:

1. The late Osias Abesamis and the petitioner in this case cohabited as
husband and wife under the lawful contract of marriage until Osias’
passing;

2. All of Osias’ documents, including his identification cards which bear his
signature, were in possession of the plaintiff herein;

3. In order to compare the signature of the late Osias Abesamis in the alleged
Deed of Sale and his customary signature, plaintiff is requested to produce
the original copy of the Identification Cards of the late Osias Abesamis;

Other reliefs just and equitable are likewise prayed for.

General Tinio, Nueva Ecija. 10 January 2023.

ELIJAH B. BACTOL
Counsel for the Defendant
THE HONORABLE BRANCH CLERK OF COURT
Municipal Trial Court
General Tinio, Nueva Ecija

Please submit the foregoing Motion for the favourable consideration of this
Honorable Court as soon as practicable upon receipt thereof. Thank you.

ELIJAH B. BACTOL

Copy Furnished by personal service:

Atty. JESSA M. BONTAGEN

Public Attorney’s Office
Gapan City District
2nd Floor, Hall of Justice Bldg., Bayanihan
Gapan City, Nueva Ecija