Republic of the Philippines

REGIONAL TRIAL COURT

7th JUDICIAL REGION
BRANCH 65
Talisay City, Cebu

JAY C. GINGOYON
Petitioner,
CIVIL CASE NO. TCV-2017-320
FOR: Declaration of Absolute
-versus- Nullity of Marriage under
Article 36 of the Family Code
LEAH D. VILLANEA
Respondent.

X--------------------------------------x

MOTION TO WITHDRAW PETITION

PETITIONER, by himself, to this Honorable Court respectfully moves to

withdraw as he hereby withdraws his Petition for declaration of absolute
nullity of marriage on the following grounds: 1) that he has transferred
residence in Bacoor City, Cavite for two (2) years already since year 2018;
and 2) that due to financial difficulties and distance, he can no longer
religiously pursue the said petition; 3) that the respondent had not filed any
responsive pleading; and 4) that he already withdrawn and terminated the
services of his counsel.

PRAYER

WHEREFORE, on the grounds afore-cited, it is respectfully moved and

prayed of this Honorable Court that the instant petition be ordered
withdrawn.

January 30 2020, Bacoor City to Talisay City, Cebu.

Jay C. Gingoyon
Petitioner/Movant
 NOTICE OF HEARING

The Clerk
RTC, Branch 65
Talisay City, Cebu

GREETINGS:

Please submit the foregoing NON-LITIGOUS MOTION for the consideration

and immediate approval of the Honorable Court sans further arguments or
appearance from Counsel immediately upon receipt hereof.

Jay C. Gingoyon
Petitioner/Movant

Copy furnished:

OFFICE OF THE SOLICITOR GENERAL

No. 134 Amorsolo St., Legaspi Village,
Makati City

OFFICE OF THE CITY PROSECUTOR

Talisay City, Cebu

Leah D. Villanea
Ai- Ai General Trinio, GMA Cavite

Explanation

Due to the distance of the addressee and for lack of available

messenger, the said motion was served by registered mail.

Jay C. Gingoyon
Petitioner/Movant
JAY C. GINGOYON
(Bacoor na Address ni sir Jay ditto)

January 30, 2020

Atty. Juan Dela Cruz

(Address ni Atty. Ditto)

Dear Atty. Dela Cruz,

I am writing to inform you that I shall no longer be requiring your legal

services and counsel. Our lawyer-client relationship shall expire and thereby
terminated effective today January 30, 2020.

While I appreciate all the time and effort that you have put in to get my
legal affairs in order, I find that there is no need for me to continue availing
your services as my counsel. Therefore, I unfortunately have to terminate
the need for your legal services considering that I have already transferred
my residence in Bacoor City, Cavite since year 2018.

Should there be any questions regarding my decision to discontinue your

legal services, please feel free to reach me via phone (09073421663) or
email address (Jay_Gingoyon@yahoo.com).

Thank you very much for your kind understanding regarding this matter. I
wish you all the best for your future endeavors.

Sincerely,

Jay Gingoyon