Republic of the Philippines

REGIONAL TRIAL COURT

Branch 47
Puerto Princesa City, Palawan

PEDRO MANZANO
Plaintiff, Civil case No. 5524

-versus-
For: DAMAGES

JUAN DE CASTRO
Defendant
x --------------------------------------x

MOTION TO CITE WITNESS FOR CONTEMPT

PLAINTIFF, by counsel and to this Honorable Court respectfully

alleges:

1. Plaintiff is of legal age and with residence at 335 Malvar Street,

Puerto Princesa while respondent is also of legal age and wit residence
at 433 Rizal Avenue, Puerto Princesa City where he may be serve with
summons and other legal processes.

2. Plaintiff is the Plaintiff I the above captioned case.

3. On November 3, 20103, upon plaintiffs application, the court

issued a subpoena for respondent to appear and testify on December 3,
2013 before the Honorable Court, and said subpoena was served on him
on November 15, 2013 by the sheriff, per letters return. Certified true
copies of the subpoena and the sheriffs return are attached hereto as
Annexes A and B, respectively.

4. Respondent did not honor the subpoena, as he did not appear

on the date, time and place indicated in said subpoena, thereby delaying
plaintiffs presentation of his evidence, as respondent would have been
plaintiffs last witness.
 WHEREFORE, plaintiff prays that after respondent shall have been
given the opportunity to be heard, judgment be rendered punishing him
for indirect contempt of court for willful defiance and disregard of the
subpoena served on him on November 15, 2013.
Puerto Princesa City, December 12, 2013.

ATTY. ARNEL S. BELARMINO

Counsel for the Plaintiff
Bgy. Tanglaw, Puerto Princesa City
Roll No. 75648
IBP No. 0457 - Palawan,
PTR No. 11456788, issued on April
13, 2012,
MCLE Compliance Cert. No. 66587

VERIFICATION AND CERTIFICATION

AGAINST FORUM SHOPPING

I, PEDRO MANZANO, of legal age and with residence at Lagan St.

Puerto Princesa City, after having been duly sworn, depose and say:

1. That I am the plaintiff in the above entitled complaint.

2. That I have caused the preparation by my counsel of said

complaint.

3. That I have read the allegations therein contained, and that

the same are true and correct of my personal knowledge or
based on authentic records.

4. That I have not theretofore commenced any action or filed

any claim involving the same issues in any court, tribunal or
quasi-judicial agency and, to the best of my knowledge, no
such other action or claim is pending therein; and if I should
thereafter learn that the same or similar action or aclim has
been filed or is pending to the court wherein the aforesaid
complaint or initiatory pleading has been filed.
 Witness my hand this 23rd day of October 2013 at Puerto Princesa
City, Palawan.

PEDRO MANZANO
Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, A Notary public in

and for the City of Puerto Princesa and the Province of Palawan this 24 th
day of October 2013. Affiant personally came and appeared with
Drivers License ID No. issued by the Land Transportation Office and
valid until May 1, 2015, at Puerto Princesa City, bearing his photograph
and signature, known to me as the same person who personally signed
the foregoing instrument before me and avowed under penalty of law to
the whole truth of the contents of said instrument

ATTY. ARNEL S. BELARMINO

Notary Public
Until December 31, 2014