Entry of Appearance

Good Morning Your Honor, I am ANA SAMANTHA ISABELA P. PARUNGAO , together with
me is MARIA ISABEL J. INDUNAN. We are student-associates from the Ateneo Legal Services
Center respectfully appearing for the plaintiff Aida Flores under the direct control and
supervision of Atty. LEO ANGELO MIGUEL R. AÑONUEVO.

When asked where our witness is:

● Your honor, in the last hearing, the Honorable Court, upon the presentation of the plaintiff
of the representative from the DENR, Mr. Erwin G. Jaoguico scheduled the next hearing
for the presentation of the plaintiff’s next witness.
● After the said hearing, the plaintiff immediately went to seek and re-establish the
communication with the supposed next witness, Mr. Sonny Taculao.
● However, from the plaintiff’s efforts in trying to touch base with several neighbors the
plaintiff received news that Mr. Sonny Taculao, has moved to his province of Abra.
● Due to the health condition of the plaintiff, and the fact that she is presently living in
Antipolo, Rizal the entire time of the COVID pandemic, the plaintiff was only able to
visit the residence of Mr. Sonny Taculao in Makati last week.
● It was then that she was informed of the immediate family of Mr. Sonny Taculao that the
said witness is presently detained in New Bilibid Prison, Muntinlupa for a case of
Homicide.
● Given that plaintiff is in need of the testimony of Mr. Sonny Taculao, the plaintiff is thus
constrained to seek the assistance of the Honorable Court for the issuance of a subpoena
for the instant case which we filed through LBC Service pursuant to Section 3 of Rule 13
of the Revised Rules of Court1 in relation to OCA Circular No. 54-20232 and in the
interest of expediency, the foregoing motion is likewise served by electronic mail.

Possible Opposition from Opposing Counsel/Judge

Q: Why did you only file the request for a subpoena yesterday?

1
Section 3. Manner of filing. — The filing of pleadings and other court submissions shall be made by:
(a) Submitting personally the original thereof, plainly indicated as such, to the court;
(b) Sending them by registered mail;
(c) Sending them by accredited courier; or
(d) Transmitting them by electronic mail or other electronic means as may be authorized by the Court in places where the
court is electronically equipped.

In the first case, the clerk of court shall endorse on the pleading the date and hour of filing. In the second and third cases, the
date of the mailing of motions, pleadings, and other court submissions, and payments or deposits, as shown by the post
office stamp on the envelope or the registry receipt, shall be considered as the date of their filing, payment, or deposit in
court. The envelope shall be attached to the record of the case. In the fourth case, the date of electronic transmission shall be
considered as the date of filing.
2
Accreditation of LBC Express, Inc. as a Courier Service Provider nationwide for a period of one (1) year, from 1
February 2023 to 31 January 2024.
A: Your Honor we were clarifying the information given to us by the relatives of the witness
because at first, they said that the witness is imprisoned in Muntinlupa. We had to clarify if it is
in Muntinlupa City Jail or in the New Bilibid Prison.

Q: Are there no other available witnesses?

A: Initially we were inclined to present Mr. Puebla but his whereabouts are unknown. After
learning that our next witness is in jail, we also contacted other family members of Sonny
Taculao who were also neighbors of our client before. However they are unavailable and are
residing in Cavite.

Q: You had 3 months to prepare for this hearing. How come you still have no witness?
A: Your honor, this unforeseen event led us to this situation. We plead to this honorable court for
the purpose of equity and justice to grant our request for issuance of a subpoena for our last
witness, who, unknown to our client, was imprisoned in New Bilibid Prison.

Q: If ever I grant the motion, what is Sonny Taculao going to testify on? Is he really a
material witness?
A: The purpose of his testimony is to prove that throughout the years Aida has exercised her
ownership over the subject land in Pembo. He would also testify as to his knowledge on Aida
acquiring the property from her brother, who was one of the original assignees of the land.

From the interview [help pakiformulate as answer wahaha]

● Papatunayan niya na umpisa pa lang alam na niya na ako ang nagmamay ari ng lupa na
mula sa kuya ko nagkaroon ng waiver yun
● Malapit lang po ba siya sa tinitirhan niyo?
○ Magkatabi lang yung block namin
● Doon kami tumutuloy noong inaayos ko ang lote ko sa bahay nila
● Nakikituloy kami doon kasi yung tatay niya noon ang group leader ng lupa so pinatuloy
nila kami doon noong inaayos namin.