REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch 46
PEOPLE OF THE PHILIPPINES, Crim. Case No. R-PSY-19-00003
Plaintiff,

For: The crime of MURDER (Art.

-versus- 248 of the RPC)

VANESSA GRACE VALUIS AND Crim. Case No. R-PSY-19-00004

MARY JANE DIAGRO,
(BOTH ARRESTED) For: The crime of ARSON (Art.
                            Accused, 320 of the RPC as amended PD
1613)
x- - - - - - - - - - - - - - - - - - - - - - -x

Pasay City
MOTION FOR CONSOLIDATION

The People, by the undersigned, unto this Honorable

Court, most respectfully state that:

1. On 3 February 2020, the Office of the City Prosecutor

of Pasay City found probable cause to file the
respective Informations in the two (2) above-cited
cases after conducting preliminary investigation.

2. These cases arose from one and the same incident.

3. Consequently, it is appropriate to consolidate the

instant cases so that they can be tried and heard
jointly by the handling judge so as to save time and
effort, in line with the Supreme Court A.M. No. 16-
0101-RTC Re; Consolidation Lumping of Newly-Filed
Cases prior to Raffling.

PRAYER

WHEREFORE, it is most respectfully prayed of to this

Honorable Office that the instant cases be consolidated and
raffled to one court.

Other reliefs just and equitable are also prayed for.

 Pasay City, Philippines, 3 February 2020.

CHRISTINE H. FRESNOZA
Senior Assistant City Prosecutor
Roll of Attorneys No. 123456
IBP No. 123455/15 April 2015/Manila
PTR No. 258968/18 April 2016/Manila
MCLE No. III-0002894
Valid until September 17, 2022

APPROVED FOR THE CITY PROSECUTOR:

ANGELICA CRISGAR B. RAMOS

Senior City Prosecutor
Chief, Sixth Division
Roll of Attorneys No. 124567
IBP No. 123457/15 April 2015/Manila
PTR No. 278984/18 April 2016/Manila
MCLE No. VI-0002395/11-21-17
Valid until September 20, 2022

Copy furnished:
1. GIAN DE GUZMAN – Pasay City
2. VANESSA GRACE VALUIS AND MARY JANE DIAGRO –
Pasay City thru counsel ATTY. AHREEN KIELA
BUENCONSEJO
3. FLORENA CAYUNA & JUSTINE BLANCHE VERA CRUZ –
Pasay City

NOTICE

HONORABLE CLERK OF COURT

OFFICE OF THE EXECUTIVE JUDGE
REGIONAL TRIAL COURT
PASAY CITY

GREETINGS:
 Please submit the foregoing motion for the kind
consideration and approval of this Honorable office
immediately upon receipt hereof.

Pasay City, Philippines, 3 February 2020.

ANGELICA CRISGAR B. RAMOS

Senior City Prosecutor
Chief, Sixth Division
Roll of Attorneys No. 124567
IBP No. 123457/15 April 2015/Manila
PTR No. 278984/18 April 2016/Manila
MCLE No. VI-0002395/11-21-17
Valid until September 20, 2022