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  • Motion For Consolidation

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    Kai Pontanar
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    This motion seeks to consolidate two related criminal cases against Nerissa Paz Tabhan Montealto for slight physical injuries. The motion argues that the two cases involve the same parties and intertwined issues and facts. Both cases are currently at the trial stage with the prosecution's initial presentation of evidence. Consolidating the two cases in the same court branch would avoid unnecessary costs and delays and allow for the expeditious resolution of the issues involved.

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    Motion for Consolidation

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    This motion seeks to consolidate two related criminal cases against Nerissa Paz Tabhan Montealto for slight physical injuries. The motion argues that the two cases involve the same parties and intertwined issues and facts. Both cases are currently at the trial stage with the prosecution's initial presentation of evidence. Consolidating the two cases in the same court branch would avoid unnecessary costs and delays and allow for the expeditious resolution of the issues involved.

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    © All Rights Reserved
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    178 views2 pages

    Motion For Consolidation

    Uploaded by

    Kai Pontanar
    This motion seeks to consolidate two related criminal cases against Nerissa Paz Tabhan Montealto for slight physical injuries. The motion argues that the two cases involve the same parties and intertwined issues and facts. Both cases are currently at the trial stage with the prosecution's initial presentation of evidence. Consolidating the two cases in the same court branch would avoid unnecessary costs and delays and allow for the expeditious resolution of the issues involved.

    Copyright:

    © All Rights Reserved
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    of 2

    REPUBLIC OF THE PHILIPPINES

    REGIONAL TRIAL COURT


    SEVENTH JUDICIAL REGION
    REGIONAL TRIAL COURT
    CEBU CITY
     
     
     
    CARESSA MAE L. SUPERFICIAL,
                           Plaintiff,
     
    -versus-                 CIVIL CASE No.
    FOR: Interpleader   
     
    HERWEN P. RIO and
    MARY GRACE O. RIO,
                                          Defendants.
    X––––––––––––––––––––––X

    MOTION TO CONSOLIDATE TRIALS OF RELATED OFFENSES


    (Section 22, Rule 119, Rules of Criminal Procedure)

    The ACCUSED, Nerissa Paz Tabhan Montealto, by the undersigned


    counsel, respectfully moves to consolidate the trials of the instant criminal case
    with the related criminal case now pending in Branch 8 of this Court, under Hon.
    Grace M. Veloso – Fernandez, docketed as Criminal Case No. M-CEB-18-01682-
    CR and entitled “People vs. Nerissa Paz Tabhan Montealto” for Slight Physical
    Injuries, which is the related criminal case with the lower docket number. The
    instant criminal case and the aforecited Criminal Case No. CEB-18-01682-CR
    pending in Branch 8 of this Court, involve the same parties with intertwined issues
    and subject matters and are both at the trial stage, particularly at the initial
    presentation of evidence for the prosecution.

    WHEREFORE, it is respectfully prayed that the two cases be consolidated


    in the Municipal Trial Court In Cities Branch 8, Cebu City to avoid unnecessary
    costs or delay and to serve the best interests of the parties and to settle
    expeditiously the issues involved.

    City of Cebu, Philippines, October 18, 2018.

    ATTY. KATRINA N. PONTANAR


    PTR No. 0925937 (01/15/2020, Mandaue City)
    IBP NO. 2708907 (01/15/2020, Cebu City)
    MCLE Compliance No.: VII-0001468
    Attorney’s Roll No. 70728 (2018)

    REDULA SANCHEZ MONTEALEGRE


    BAUZON BRAGAT MENDOZA
    & DANLAG-LUIG LAW OFFICES
    Counsel for the Plaintiff
    Suites 301-304, C & F Ramirez Building II,
    S. B. Cabahug Street, Centro, Mandaue City, Cebu
    6014
    Telefax No. (032) 238-4281

    Copy Furnished:

    ATTY. JASON C. GENOBIAGON


    Room 301, 3rd Floor, No. 30
    Goodwill Building, Osmena Boulevard
    Cebu City, Cebu, 6000

    Registry Receipt No:_________________


    Date: _____________________________

    EXPLANATION OF SERVICE BY MAIL

    The undersigned counsel most respectfully manifests that a copy of


    Motion To Consolidate Trials of Related Offenses for the defendant, Mary Grace
    O Rio, was served to the above-named address by registered mail in lieu of
    personal service because of lack of manpower to effect the personal service.

    ATTY. KATRINA N. PONTANAR

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