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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


THIRD JUDICIAL REGION
_______________________
BRANCH ___

_________________________,
Petitioner,

-versus- CIVIL CASE No.


_______________________
For Declaration of Nullity of
Marriage
_________________________,
Respondent.
x-----------------------------------------------x

MANIFESTATION AND MOTION

PETITIONER, through counsel, respectfully states that:

1. Per the records of this case, the last known address of


respondent is:

_________________________, Mariveles, Bataan

2. However, the mail matters of the undersigned and of


the Honorable Court addressed to respondent remain unserved
and are returned to sender with notation either “moved out” or
“addressee abroad”. Simply said, herein respondent is not
found in his given address, which causes the delay of the
proceedings of this case.

3. Last February 8 and 19, 2019, respondent sent


parcels/packages for his son via private courier LBC. In said
parcels/packages, the following address appears as the address of
respondent _________________________, as sender:

_________________________, Mariveles, Bataan

The original of the two (2) LBC parcel/package pouches


bearing the above-mentioned additional address of respondent are
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attached to the original of this Manifestation and Motion and made


integral parts hereof as Annexes “A” and “A-1” respectively.

4. On this note, petitioner requests/move that notices and


processes of the Honorable Court be also sent to respondent at
_________________________, Mariveles, Bataan, his address
as reflected in the parcels/packages that he recently sent.

PRAYER

WHEREFORE, it is respectfully prayed that the foregoing


Manifestation be duly noted and made part of the records of this
case.

It is respectfully prayed also that notices and processes of the


Honorable Court be sent to respondent’s additional address at
_________________________, Mariveles, Bataan.

Angeles City, Philippines, 27 March 2019.

Counsel for the Petitioner

NOTIFICATION AND COPY FURNISHED:

Respondent RR NO. ________________


148 Old San Jose, Dinalupihan, Bataan _____ March 2019
Main Post Office, A.C.

OFFICE OF THE SOLICITOR GENERAL


134 Amorsolo St., Legaspi Village, RR NO. ________________
Makati City, 1229 _____ March 2019
Main Post Office, A.C.

OFFICE OF THE CITY PROSECUTOR Received by:


Angeles City ___________________________
Hall of Justice, Pulung Maragul, ____ March 2019
Angeles City
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The Clerk of Court


RTC Br. ____,
________________________

Greetings:

Kindly submit the foregoing motion for the consideration and


approval of the Honorable Court immediately upon receipt hereof.

_________________________

EXPLANATION

(in compliance with Section 11, Rule 13 of the 1997 Rules of Civil
Procedure)

Copies of the pleading to which this explanation is appended was:


 filed with this Honorable Court by registered mail;
 sent to Office of the Solicitor General and the adverse counsel
by registered mail; due to the following reason/s:
 the distance between this Honorable Court and counsel’s
office which makes personal filing of the pleading/motion
impracticable;
 the distance from the office of counsel to the Office of the
Solicitor General and adverse counsel which makes personal
service impracticable;
 lack of office personnel to effect personal service;
 time constraints

_________________________