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Motion For Collusion Investigation - Cadavos

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Republic of the Philippines

REGIONAL TRIAL COURT


7th Judicial Region
Branch 62, Oslob Cebu

MARCOS C. CADAVOS
Petitioner, CIVIL CASE NO. OS-17-274
FOR: Declaration of Nullity of Marriage
-versus- under Article 36 of the Family Code

CAROLINA Y. MESA
Respondent.
x-------------------------------/

MOTION FOR COLLUSION INVESTIGATION

Petitioner, by the undersigned counsel, and unto this Honorable Court most
respectfully states that:

1. The Office of the Solicitor General already entered its appearance and
already authorized the Office of the Provincial Prosecutor of Cebu to appear
in its behalf for this case;

2. The respondent was already served with the summons through publication
on June 18, 2018 as evidence by the Affidavit of Publication hereto attached

3. To date, Respondent never filed her Answer or any responsive pleading with
respect to the Complaint filed against her

4. The reglementary period to file her Answer already expired and until now,
respondent failed to file his Answer or any responsive pleading to the
Petition;

5. Petitioner is ready to submit to an investigation to be conducted by the


Honorable Handling Public Prosecutor to determine whether or not collusion
exist between the parties.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of


this Honorable Court to order the handing public prosecutor to conduct an
investigation in order to determine the existence or non-existence of
collusion between the parties in this case.

Other reliefs consistent with law, justice, and equity are likewise
prayed for.
Cebu City Philippines for Oslob Cebu. July 23 2018.

Respectfully submitted.

ISIDRO L. SARONA JR.


( COUNSEL FOR THE PETITIONER)
RM. 303 ANICETA BLDG., OSMENA BLVD., CEBU CITY
IBP NO. 1053040;12/20/16-CY 2017;CEBU PROVINCE CHAPTER
PTR NO. 13259587;12/20/16-CY 2017;CEBU PROVINCE
ROLL OF ATTORNEYS NO. 61786
MCLE COMPLIANCE NO. V-0006494 VALID UNTIL 4/14/2019
TEL NO. 254-8455
EMAIL ADD: isidrojr.sarona@yahoo.com

The RTC Branch Clerk


RTC Branch 62 Oslob Cebu

Please submit the foregoing Motion to the Honorable Court immediately


upon receipt thereof sans the appearance of counsel for its due consideration.

Thank You.

Copy furnished:

Office of the Cebu Provincial Prosecutor


Palace of Justice, Capitol Site Cebu City

Office of the Solicitor General


134 Amorsolo St., Legaspi Village
1229 Makati City

EXPLANATION

This Motion is filed and furnished through mail courier, personal service is
impractical due to distance.

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