Republic of the Philippines

Department of Justice
ILOILO CITY PROSECUTION OFFICE
Iloilo City

RICHARD TUMAGAN TORRIGUE

Complainant,

-versus- NPS Docket No.: VI-10-INV23A-00001

For: Violation of B.P. 22 (Bouncing
Checks Law)

ELLEN VALE ABORDO RIVERA,

Respondent.
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URGENT MOTION FOR EARLY RESOLUTION

Complainant, by counsel, to the Honorable Prosecutor, respectfully

states that:
1. The above-entitled case is a criminal action for violation of
the bouncing checks law under Batas Pambansa Bilang 22,
which was filed on January 5, 2023;
2. One Hundred Twenty Days (120) have already lapsed but no
action or resolution has been done or promulgated;
3. The private complainant is a seafarer who is about to embark
on board his assigned vessel within the month of May 2023;
4. The private complainant and herein counsel has received an
information from a reliable source that the respondent will
migrate to Canada;
5. Thus, the undersigned is requesting for the early resolution of
the above entitled case so as not to frustrate the ends of justice.

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Office that a Resolution be rendered in this case based on the
evidence presented.

Other just and equitable reliefs are likewise prayed for.

Respectfully submitted this 8th day of May 2023, Iloilo City.

1
 DUREMDES NAVA LAW FIRM

ATTY. STEWART PAUL T. TORRE

Roll of Attorneys No.: 67265
IBP No.:258923-Pasay City, Jan. 03, 2023
PTR No.:7692746-Iloilo City, Jan. 4, 2023
MCLE Compliance VI-0010210
Duremdes Nava Law Office
A&L bldg.., E. Lopez St., San Vicente, Jaro, Iloilo City
Mobile Phone No.: 09478929387

NOTICE OF HEARING

Honorable City Prosecutor

Office of the City Prosecutor

Greetings:

Please take notice that the undersigned will submit the foregoing
motion for the Honorable Office’s consideration immediately upon receipt
hereof without further oral arguments and without presence of
counsels/parties. Thank you.

ATTY. STEWART PAUL T. TORRE

EXPLANATION

Copies of the foregoing Motion were filed and served through registered
mail due to the distance of the offices involved and the lack of messengerial
personnel.

ATTY. STEWART PAUL T. TORRE

Copy furnished:

ELLEN VALE ABORDO RIVERA

Lot 4, Block 6, Phase 1, Deca Homes Subdivision,
Barangay Balabag, Santa Barbara, Iloilo.