Republic of the Philippines

REGIONAL TRIAL COURT

Fifth Judicial Region
BRANCH 43
Virac, Catanduanes

SALVADOR TINDUGAN, ET. CIVIL CASE NO. 2598

AL.,,
Plaintiffs,

- versus -

ROSITA TEJADA, ET.AL.,

Defendants.
x--------------------x

MOTION WITH MANIFESTATION

Plaintiffs, thru the undersigned counsel and to the Honorable Court

respectfully avers that:

1. On August 14, 2020, the undersigned received the Pre-Trial Order of this
case;

2. However, upon perusal of the said Pre-Trial Order, there were some
omissions or error in the Documentary evidence and Testimonial
evidence on the part of the plaintiffs, and the Court has given 15 days the
parties to make necessary corrections upon receipt of the Order, hence
within the period to file this manifestation for correction;

3. That in Documentary evidence, the (reserved) Judicial Affidavit of

Salvador Tindugan was not included in the exhibits and in Testimonial
evidence, the representative from PENRO was not also included as one
of the witnesses of the Plaintiffs as these errors or omissions are very
crucial in this case;

4. That the undersigned respectfully manifest to make necessary corrections

in the Pre-Trial Order that the Judicial Affidavit of Salvador Tindugan be
included in the Documentary evidence as Exhibit “Q” and Representative
from PENRO be included as one of the witnesses of the Plaintiffs;
 5. This motion is not intended to unduly delay the disposition of the above-
entitled case but only for the reason above-mentioned.

WHEREFORE, in view of the foregoing, it is most respectfully prayed to

this Honorable Court that the Pre-Trial Order dated August 13, 2020 be
corrected and include the above-mentioned evidence.

Such other relief just and equitable under the premises is likewise prayed
for.

Respectfully submitted, August 28, 2020 at Virac, Catanduanes.

PUBLIC ATTORNEY’S OFFICE

Catanduanes Provincial Office
Virac, Catanduanes

by:

JANETH B. ALVAREZ
Public Attorney I
Roll No. 71432
IBP OR NO. 109654/January 10, 2020/Manila
MCLE VI Compliance No. 0021222

NOTICE OF HEARING

The Clerk of Court

RTC Branch 43
Virac, Catanduanes

Greetings:
Please submit the foregoing motion to the Honorable Court for its approval
consideration upon receipt hereof.

JANETH B. ALVAREZ

CC: ATTY. GIL G. TAWAY IV

Suite 1902, España Tower,
2203 España Boulevard
 City of Manila
EXPLANATION OF SERVICE

This Motion with Manifestation was not served personally on counsel for the
Defendants and on the Honorable Court and service by electronic mail was
resorted since the counsel for the Plaintiff is on leave and currently outside the
Province of Catanduanes, the distance involved lack of sufficient time manpower
to effect personal filing and service.

JANETH B. ALVAREZ