Republic of the Philippines

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
BRANCH 4
Baguio City

Xxxx , Civil Case No._____________

Petitioner,

-versus- For: Declaration of Nullity of

Marriage Based on Psychological
Incapacity
xxx,
Respondent,

x-----------------------------------------------x

EX-PARTE
MOTION TO ALLOW PETITIONER TO
TESTIFY IN ADVANCE

WITH ALL DUE RESPECT UNTO THIS HONORABLE COURT

Petitioner, through counsel, unto this Honorable Court, respectfully aver:

1.The above- entitled was filed last January 20, 2017.

 2.The petitioner is in the Philippines but he is due to leave for Qatar on June
26, 2017, to continue his work, a copy of his electronic ticket and passport are
hereto attached as Annexes “A” and “B”.

3. In view of the foregoing, petitioner through counsel, respectfully prays

that he be allowed to testify in advance preferably on June 22, 2017 at 11:00
o’clock in the morning as he will be leaving for Qatar by June 26, 2017.

4. This motion is not to go against or disregard the calendar of this Honorable

Court but due to the foregoing reason.

5. Petitioner, through counsel, respectfully offers her apology for the

inconvenience the early scheduling of the hearing will cause to the Honorable
Prosecutor and to the Honorable Court.

RELIEFS

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

Court to give due course to the foregoing and to allow petitioner to testify in
advance preferably on June 22, 2017 at 11:00 o’clock in the morning.

Further prays for such other reliefs and remedies just and equitable under
the circumstances.

Baguio City, Philippines, June 20, 2017.

xxxx
Law Office
Counsel for the Petitioner
Rm. 220 Lyman Ogilby Centrum
 358 Magsaysay Avenue, Baguio City

By:

Xxxx

NOTICE

THE CLERK OF COURT

RTC, Br.4
Baguio City

PROS. MARGARITA MANALO

Office of the City Prosecutor
Justice Hall, Baguio City

Greetings:

Please be notified that undersigned will submit the foregoing motion for the
kind consideration and approval of the Honorable Court on June 21, 2017 at 8:30
o’clock in the morning, without any further oral argument.

xxx

EXPLANATION: Due to the distance between Baguio City Makati City and
Davao City and the lack of personnel to do personal service the foregoing motion
was served to Office of the Solicitor General and to respondent through registered
mail.
 xxxx

CC: PROS. MARGARITA MANALO

Office of the City Prosecutor
Justice Hall, Baguio City