Republic of the Philippines

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch 253, Las Piñas City

SPOUSES SALVADOR
BATOLINIO and AMOR
P. BATOLINIO,
Plaintiffs,
Civil Case No. LP-08-120
For: Cancellation of Title,
- versus - Specific Performance and
Damages
NICEFORA U. MINOZA
FEDELINE BALBOS .
LEONILA BRIONES
MARIA ELENA SIBULAN
YOLANDA VARGAS
FILIPINAS V. VELEZ
PHILIPPINE SAVINGS BANK,
INC.
IAN FRANCIA
CHARITO ASUNCION
Defendants.

URGENT MOTION FOR THE ISSUANCE OF

SUBPOENA DUCES TECUM AND AD TESTIFICANDUM

The Plaintiffs, through the undersigned counsel, respectfully requests for

the issuance and service of subpoena ad testificandum and duces tecum to
MARIVIC T. MATIONG (Document Examiner) and CAROLYN J.
MOLDEZ-PITOY (Chief, Questioned Documents Laboratory Division) of
the NATIONAL BUREAU OF INVESTIGATION, Manila – with office
address at NBI Taft Avenue, Ermita, manila, Philippines – commanding them,
or their authorized representatives, to appear and testify before the Honorable
Court at the next scheduled hearing; and, then and there, to bring and produce
before the Honorable Court the original copies of the following documents:

a. The Questioned Documents Report (QDR) No. 412-918-A (Ref.

QD Case Nos. 227-518; 16-114 & 486-1011);

b. The Certificate of Full Payment submitted by the Plaintiff to the

NBI concerned, wherein the signature of the former was marked
as “Q-AB” by the latter for purposes of identification in its QDR
and,

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 c. The Standards of Comparison consisting of the sample specimen
signatures of the Plaintiff appearing on the documents and which
for purposes of identification in the QDR were marked as “S-1 to
S-30”.

I. PRAYER

WHEREFORE, premises considered, it is respectfully prayed that a

Subpoena Duces Tecum and Ad Testificandum be issued to MARIVIC T.
MATIONG (Document Examiner) and CAROLYN J. MOLDEZ-PITOY
(Chief, Questioned Documents Laboratory Division) of the NATIONAL
BUREAU OF INVESTIGATION, Manila, for the next scheduled hearing.

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

RESPECTFULLY SUBMITTED.

Quezon City, 3 June 2019.

II. NOTICE OF HEARING

The Honorable Branch Clerk of Court

RTC Branch 253, Las Piñas City

Greetings:

Please be informed that the foregoing motion shall be submitted for the
consideration and approval of the Honorable Court immediately upon receipt
hereof.

ATTY. JAYSON V. ABRERA

Counsel for Plaintiff
PTR No.5881667 | 02-05-18 | Quezon City
IBP Lifetime No: 017086 (RSM)
MCLE Compliance no. IV-0009361
Valid until April 14, 2022
Roll of Attorneys No. 67749

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Copy Furnished:

ATTY. SOTERO C.
MENDOZA
Counsel for Defendant Nicefora U.
Minoza
No. 14 Oak Street, Mahogany Park
I Subdivision Marikina Heights
1810, Marikina City

ATTY. ALFREDO V.
ZERRUDO, JR
Counsel for Defendant Fedeline
Balbis
#1030-A Pasay Road corner Ponce
Street
San Lorenzo Village, Makati City

ATTY JOSE M. MAUEL, JR.

ATTY. ARNEL Z. RIVERA
Counsel foe Defendants Philippine
Savings Bank,
Leonardo Decini, Charito
Asuncion, and Ian Francia
9th Floor, PSBank Building
777 Paseo de Roxas Avenue corner
Sedeno Street
Makati City

ATTY. HERMINIO T. UBANA,

SR.
Counsel for Defendants Leonila
Briones, Maria Elena SImbulan,
Yolanda Vargas and Filipinas Velez
No.2 F. Ocampo Avenue, Manuela
IV Subdivision
Pamplona III, 1740 Las Pinas City

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