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
2
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 148 Old San Jose, Dinalupihan, Bataan OFFICE OF THE SOLICITOR GENERAL 134 Amorsolo St., Legaspi Village, Makati City, 1229
OFFICE OF THE CITY PROSECUTOR Angeles City Hall of Justice, Pulung Maragul, Angeles City
RR NO. ________________ _____ March 2019 Main Post Office, A.C.
RR NO. ________________ _____ March 2019 Main Post Office, A.C. Received by: ___________________________ ____ March 2019
3
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
_________________________