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Motion To Admit

This motion requests that the provincial prosecutor admit the belated affidavits of two witnesses, Keken Baluran and Eduardo Ballos Sr., in the case of Enrique B. Yap Jr. versus Vanny Domingo et al. for violation of the Revised Penal Code. The motion states that the two witnesses were unable to submit their affidavits on the original date due to being offshore on fishing boats with no means of communication. Admitting the late affidavits is argued to be in the interest of justice to corroborate the defense arguments. The motion was filed in General Santos City on August 18, 2022 by the defense counsel Clemente A. Panganduyon on behalf of the respondents

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CLEMENTE PANGANDUYON
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34 views2 pages

Motion To Admit

This motion requests that the provincial prosecutor admit the belated affidavits of two witnesses, Keken Baluran and Eduardo Ballos Sr., in the case of Enrique B. Yap Jr. versus Vanny Domingo et al. for violation of the Revised Penal Code. The motion states that the two witnesses were unable to submit their affidavits on the original date due to being offshore on fishing boats with no means of communication. Admitting the late affidavits is argued to be in the interest of justice to corroborate the defense arguments. The motion was filed in General Santos City on August 18, 2022 by the defense counsel Clemente A. Panganduyon on behalf of the respondents

Uploaded by

CLEMENTE PANGANDUYON
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

Department of Justice
National Prosecution Service
OFFICE OF THE PROVINCIAL PROSECUTOR
Alabel, Sarangani Province
(083) 5082250

ENREQUE B. YAP, JR., NPS DOC. NO. XII-07-INV-


Complainant, 22G – 00333

-versus- -for-

VANNY DOMINGO, ET. AL., Violation of Art. 315 2(a) of RPC as


Respondents, amended by Sec. 85 of RA 10951
x-----------------------------------x

MOTION TO ADMIT

Respondents, through counsel, unto this Honorable Office of


the Provincial Prosecutor, respectfully submits this Motion and states
THAT:

1. Respondents, as well as their witnesses, subscribed and


submitted, respectively, their Counter Affidavits and Affidavits before
this Honorable Office on August 11, 2022;

2. However, two (2) witnesses were not able to appear


during that day because they were still onboard on their fishing boats
and the was no means to communicate with them;

3. In the interest of justice, we intend to belatedly submit


their affidavits attached herein to corroborate our defenses.

WHEREFORE, premises considered, it is respectfully prayed for


that this Honorable Office of the Provincial Prosecutor considers the
belated submission and the affidavits of witness KEKEN BALURAN
and EDUARDO BALLOS, SR. be admitted.

Other reliefs just and equitable under the premises are likewise
prayed for.

Motion to Admit 1 | 2
General Santos City for the Alabel, Sarangani Province, 18
August 2022.

RESPECFULLY SUBMITTED.

CLEMENTE A. PANGANDUYON
Counsel for Respondents
Roll No. 72479/14June2019/Manila
MCLE Compliance No.: VII-0014243
IBP No.: 183475/ 03 JAN 2022
PTR No. 0032295/ 03 JAN 2022

3rd Floor, C. CZAR & Co. Building (Beside


EastwestBank), Santiago Blvd,
9500 General Santos City
clementepanganduyon@gmail.com
(0915) 356 0224

Copy furnished:

ENREQUE B. YAP
Barangay Poblacion,
Glan, Sarangani Province

Motion to Admit 2 | 2

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