REPUBLIC OF THE PHILIPPINES

6th MUNICIPAL TRIAL COURT

Santiago- San Esteban, Ilocos Sur
Santiago, Ilocos Sur
FIRST JUDICIAL REGION

PERMANENT SAVINGS AND

LOAN BANK,
Plaintiff,

CIVIL CASE NO. _________

-versus-
FOR: Collection of Sum of Money
and damages

MARIANO O. VELARDE
Defendant.
x-------------------------------------------x

MANIFESTATION WITH MOTION TO ADMIT

(Attached Judicial Affidavit and Certificate of Non-Forum Shopping of
Mariano Velarde)

Defendant, through counsel and unto this Honorable Court, most

respectfully seeks the admission of the attached Judicial Affidavit and
Certificate of Non-Forum Shopping of Mariano Velarde, and further states
that:

1. It was only on October 19, 2023 that the services of the undersigned
counsel were formally engaged by the Defendant. Forthwith, this
representation has to carefully review and evaluate the case and
interview the defendant so as to fully and ably represent the cause of
the Plaintiff and that of the defendant;

2. Unfortunately, however, the undersigned was likewise loaded with

deadlines of cases of equal importance during the said week and the
week after, thus, the unfortunate and untimely submission of the
Judicial Affidavit and Certificate of Non-Forum Shopping;
 3. The Motion is not in any way intended to deviate from the rules of
procedure and to delay the proceedings of the instant case but solely
due to the foregoing reasons;

4. It is thus respectfully pleaded of this Honorable Court that the

attached Judicial Affidavit together with its attached Exhibits and the
Certificate of Non-Forum Shopping be admitted and be made part of
the records of the case.

PRAYER

WHEREFORE, it is most respectfully prayed of this Honorable

Court that in the interest of substantial justice and to afford the defendant the
opportunity to be heard, the attached Judicial Affidavit together with the
Certificate of Non-Forum Shopping be admitted and be made part of the
records of the case.

Defendant prays for such other reliefs that are just and equitable under
the premises.

October 27, 2023, Vigan City.

ABC LAW OFFICES

By:

ATTY. JEAN CLAIRE ALMOSA

Counsel for the Plaintiff

NOTICE

THE BRANCH CLERK OF COURT

6th MUNICIPAL TRIAL COURT
Santiago- San Esteban, Ilocos Sur
Santiago, Ilocos Sur
FIRST JUDICIAL REGION
ABC LAW OFFICES
Counsel for Defendant Mariano Velarde

Greetings!

Please be notified that the foregoing MANIFESTATION WITH MOTION TO ADMIT

(Attached Judicial Affidavit and Certificate of Non-Forum Shopping of MARIANO VELARDE)
is submitted for the consideration and resolution of the Honorable Court. Thank you.