REPUBLIC OF THE PHILIPPINES

Department of Transportation and Communications

LAND TRANSPORTATION FRANCHISING REGULATORY BOARD
East Avenue, Quezon City

RICHARD C. GRIARTE CASE NO. TNVS-2018-7306

Applicant

MOTION FOR EXTENSION OF PROVISIONAL AUTHORITY

COMES NOW, the applicant, unto the Honorable Board, respectfully alleges
that:

That applicant is/are a Filipino Citizen/Corporation existing and duly organized

under Philippine laws and business address at B19 Floodway Cambridge Village, Cluster
28, Unit 1-0 Bogy., San Andres Cainta, Rizal;

That applicant/s hereby apply for the extension of issuance of a PROVISIONAL

AUTHORITY of Certificate of Public Convenience to operate a Transportation Network
Vehicle service within/on the route of METRO MANILA accessible to motor vehicle
traffic and vice versa with the use of ONE (1) unit/s to wit:

That the authorized unit/s is are hereunder described as follows and the copy of
Certificate of Registration and LTO Official Receipt is/are hereto attached as Annex “A”

Make Motor No. Chassis No. Plate No.:

MITS. MIRAGE 3A92UCG5748 MMBXNA03AFH009922 NH2124

HATCHBACK

That applicant is financially capable in maintaining the service applied for;

That applicant will comply with all the requirements for this Honorable Board and will
abide with the existing LTFRB Rules and Regulations, the Public Service Act, and other
pertinent laws/policies and;

That with consideration and approval of this application, public necessity and
convenience will be promoted in a suitable manner;

Thus, the applicant submits the copies of the following documents required by this
Honorable Board, namely:

ORDER is hereto attached marked as annex “B”

Government ID is hereto attached marked as annex “C”.

WHEREFORE, it is most respectfully prayed that after due notice and hearing this
motion for extension of ISSUANCE OF PROVISIONAL AUTHORITY be accepted and
considered. Thereafter, an order of Provisional Authority be issued by this Honorable
Board.

December 18, 2018, Pasig City

RICHARD C. GRIARTE
Applicant
 Accused,
x-------------------------------------------x

MOTION FOR RECONSIDERATION

Arresting Officer PO1 RODY DANGIWAN, unto this Honorable Office most
respectfully move to reconsider the Decision dated September 26, 2018 of the above-
entitled case, which was received on October 1, 2018, on the following consideration:

1. On September 26, 2018, the Honorable Judge HONORIO C. EBORA JR.

issued an Order for the above entitled case which, stated as follows:

Acting on the oral motion, and in view of the absence of the arresting
officer/ witness despite due notice and in accordance with the “one day-one
witness” rule, the Prosecution is deemed to have forfeited presenting its witness
today. As such, and since the Prosecution has no other witness to present, the oral
motion is hereby GRANTED.

“WHEREFORE, the instant case against accused GEORDAN LANCE

LLANA is hereby considered DISMISSED for want of evidence. “

2. On September 26, 2018 at 8:10 a.m., while I was on the way to the court for
the scheduled hearing at Branch 71, Pasig City, I met a vehicular Accident
where I have to record and settled in Barangay San Miguel where the
accident happened, attached is ANNEX “A” of the Barangay Blotter;

3. I immediately went to Branch 71, Pasig City to be the witness of case M-

PSG-18-01644-CR, however, I was not be able to attend the hearing which
has been finished and Atty. Ma. Fatimah Villanueva moved for the
dismissed of the instant case, said oral Motion has been Granted, attached
ANNEX “B”, and a zerox copy of Minutes of Court dated September 26,
2018 where I appeared at 9:26-18 only late, attached as ANNEX “C”, due to
abovementioned accident;

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court, the Order dated September 26, 2018 be reconsidered and the
foregoing Motion for Reconsideration be approved and the Decision be set aside.

City of Pasig , October 1, 2018.

 WAIVER

I, RICHARD C. GRIARTE, hereby grants authority to LTFRB, to verify the

authenticity of all the documents herein submitted together with this application from
both government and private sources.

RICHARD C. GRIAIRTE
Applicant

VERIFICATION AND CERTIFICATION

OF NON-FORUM SHOPPING

I, RICHARD C. GRIARTE, after having been duly sworn to in accordance with law
hereby depose and say that:

1. I/We am/are, the Applicant/s in the above-entitled case;

2. I/We have caused the preparation of the foregoing application
3. I/We have read the contents thereof and the same are true to the best of my
knowledge and belief;
4. I/We have not commended any other action or proceeding involving the same
issuance in any other LTFRB Office;
5. To the best of my knowledge, no such other application, petition, or pleading is
pending therein.
6. If I/we learn of the same or similar application, petition, or pleading had been filed
or is pending, I/we shall report of such fact within five (5) days from to this
Honorable Board.

RICHARD C. GRIARTE
Applicant

SUBSCRIBED AND SWORN to before me this _____ day of

________________2018, in Pasig City, exhibiting to me his/her Valid Id Driver’s License
N04-96-354827.

Witness my hand and seal.

Doc.No.______________;
Page No.______________;
Book No.______________;
Series of 2018.
 REPUBLIC OF THE PHILIPPINES
HOUSE AND LAND USED REGULATORY BOARD
QUEZON CITY

JOSEPHINE M. POBLETE
Petitioner

MOTION FOR CANCELLATION OF LIS PENDES

COMES NOW Petitioner, unto the Honorable Office, most respectfully moves_;

1. That on May 20, 1996, Mr. ANTONIO A. ALON Deputy Registry of Deeds
Inscripted Notice of Lis Pendens that an action has been commenced and is
now pending before the office of H.L.U.R.B.;

2. That the case is now in the H.L.U.R.B. arbiter

PRAYER
WHEREFORE, premises considered it is most respectfully prayed of this
Honorable Office approved the cancellation of Notice of Lis Pendens annoted in
Transfer Certificate of Title No. 691439 under entry No. 625932.

IN WITNESS WHEREOF I have hereunto set my hand and seal this

____________ day of __________, 2017 at Pasig City.
 JOSEPHINE M. POBLETE
Affiant

SUBSCRIBED AND SWORN to on this _____________ day of

_____________, 2017 at Pasig City.

Doc. No. ___________;

Page No. ___________;
Book No. ___________;
Series of 2017

REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION
METROPOLITAN TRIAL COURT
CITY OF PASIG
BRANCH 71

DELFIN C. AUSTRIA JR.,

Plaintiff, M-PSG-17-01278-SC

- Versus - - for –

MARICEL HARABA and all persons Unlawful Detainer

Claiming rights under her
Defendants.
X ---------------------------------------X

MOTION FOR EXECUTION

COMES NOW, the Plaintiff, DELFIN C. AUSTRIA, unto this Honorable

Court, most respectfully states:

1. That on December 20, 2017, the Honorable Presiding Judge

HONORIO C. EBORA JR., rendered a decision as follows:

“After a perusal of the records, the court finds and so holds

that there is a preponderance of evidence in favor of the
 plaintiff AUSTRIA as established by clear and convincing
proofs.

There is no doubt that the owner of the property has the

right to enjoy and disposed of the thing he owned, without
limitations other than those established by law. He also has
a right of action against the holder and possessor of the
thing in order to recover it. Further, he has the “right to
exclude any person from the enjoyment and disposal
thereof, such that, he may use such force as may be
necessary to repel or prevent an actual or threatened
unlawful physical invasion or usurpation of his property.”

Considering that plaintiff AUSTRIA only prayed for the

amount of not less than PHP1,000.00 for the reasonable use
of the property from January 2017 until defendant finally
vacates the premises, the amount of PHP1,000.00 is deemed
appropriate under the circumstance. Defendant HARABA
should pay the amount of PHP1,000.00 a month from
January 2017 until she finally vacates the premises.

As to Attorney’s fee’s, considering the summary nature of this

case, the court deems it prudent to award the amount of
PHP10,000.00. Plaintiff AUSTRIA is also entitled to the
payment of the cost of litigation represented by the docket
fee’s of PHP3,220.00

WHEREFORE, premises considered, judgment is hereby

rendered:

1. Ordering defendant HARABA and all persons claiming

rights under her to immediately vacate the premises located
at M. Concepcion St., Block 1, Austria Compound,
Brgy. San Joaquin, Pasig City;

2. Ordering defendant HARABA to pay PHP1,000.00 per

month as reasonable compensation on the premises counted
from January 2017 until she finally vacates the premises;

3. Ordering defendant HARABA to pay attorney’s fees in the

amount of PHP10,000.00; and

4. Ordering defendant HARABA to pay the cost of suit of

PHP3,220.00

2. There was no appeal and the Decision has become final and
executory. It is therefore imperative for the issuance of a writ of
execution.

WHEREFORE, premises considered, it is most respectfully

prayed of this Honorable Court that a Writ of Execution be issued thereto and that the
same be enforced / implemented in accordance with the Decision, aforementioned.
 Other relief and equitable under the premises are likewise
prayed for.

Pasig City 25 September 2018

DELFIN C. AUSTRIA JR.

Plaintiff
No. 180 Jabson St.,
Brgy. San Joaquin, Pasig City

Copy furnished / notice of hearing

ATTY. ISMAEL F. MEJIA

Counsel for the defendant
Unit 209 BPI Condominium,
Plaza Cervantes, Binondo, Manila

THE CLERK OF COURT

Metropolitan Trial Court
Pasig City Branch 71

Greetings,

Please take notice that the Motion forthwith shall be submitted for the
Honorable Court’s consideration and approval on ____________ at _________ a.m. /
p.m. even without further argument.

DELFIN C. AUSTRIA JR.

EXPLANATION

I have furnished copy of the foregoing motion to the addressee, by registered

mail being impractical to serve personally by reason of animosity or strained relations.

DELFIN C. AUSTRIA JR.

 SUBSCRIBED AND SWORN TO, before me this __________ day of
__________, 2018 in Pasig City, affiant exhibiting to me his Valid ID No.
______________.

Doc. No. ____;

Page No. ____;
Book No. ____;
Series of 2018
Republic of the Philippines
Department of Justice
NATIONAL PROSECUTION SERVICE
OFFICE OF THE CITY PROSECUTOR
PASIG CITY

BUDGET LANE SUPERMARKET UNDER

GOLDTEMPO COMPANY, INC. represented by,
JERVY ANTONIO y ENSOMO
-Complainant-
-versus-
ALJON GERALDEZ y RAMIREZ
-Respondent- XV-14-INQ-17A / 00020

x-----------------------------------------------------------x

MOTION FOR THE RELEASE EVIDENCE

COMES NOW, the Complainant BUDGET LANE SUPERMARKET UNDER

GOLDTEMPO COMPANY, INC. represented by JERVY ANTONIO y ENSOMO,
and unto this Honorable Office, most respectfully states:

That the COMPPLAINANT was a victim of the Accused, ALJON GERALDEZ y

RAMIREZ , for theft of ONE (1) Box containing 14 pieces of bear brand powdered milk
drink 700 grams worth PHP3031.50 in the Budget Lane Supermarket under Goldtempo
Company, Inc.;

That the abovementioned goods were impounded and in the custody of Pasig
Police Station , C. Raymundo, Canioogan, Pasig City.;
 That the Complainant most respectfully requests that the above described goods
(evidence) be released to the abovementioned Company since they have expiration date
and we need to sell them before they expired;

That he is substituting the same with the pictures of the goods;

That if granted, he undertakes to testify as required by the Honorable City

Prosecutor;

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Office that an Order be issued for the release of the abovementioned goods to
the undersigned and that the pictures be admitted instead.

Pasig City, 16 January 2017.

JERVY ANTONIO y ENSOMO

Movant

SUBSSCRIBED AND SWORN to on this ______ day of January, 2017, Pasig

City. And I have certify that I have examined the affiant, and I am satisfied that he
voluntary executed the foregoing Motion and that he fully understood the same and that
the same is his voluntary act and deed.

Assistant City Prosecutor

REPUBLIC OF THE PHILIPPINES)

CITY OF PASIG )

AFFIDAVIT OF UNDERTAKING

I, CLARK GARCIA TUAZON, of legal age, Filipino and a resident of No. 235
M. H. del Pilar Street, Palatiw, Pasig City, after having been duly sworn to in accordance
with law hereby depose and state:

That the undersigned is the representative of MILDRED NATANAUAN

TUAZON the registered owner of a motor vehicle with Plate No. RMF177, as
evidenced by its Certificate of Registration, Official Receipt pictures hereto attached as
Annexes A & B respectively;

That on January 21, 2016, said vehicle while being driven Jovanie Herman y
Dahang, got involved in an incident and as such, was impounded and in the custody of
Alitagtag, Batangas Municipal Police Station;

That as one of the conditions required for the release of the said vehicle, I hereby
undertake that I will present the same whenever I will be required to do so;

That I am executing this Affidavit to attest to the truth of all the foregoing facts
and circumstances.

IN VIEW WHEREOF, I have hereunto set my hand this ___ day of

___________, 2016 at Pasig City.
 CLARK GARCIA TUAZON
Affiant

SUBSCRIBED AND SWORN to before me this ____ day of

_____________,2016 at Pasig City, representing his Valid DL No. N03-08-000025.

Doc. No. ____;

Page No. ____;
Book No. ____;
Series of 2016

Republic of the Philippines

PROVINCIAL PROSECUTION OFFICE OF RIZAL
Taytay, Rizal

JESSIE LORD D.R. LACANILAO XV-IBC-16B-00571-72

CYRUS ROLLUDA y GALICIA
Complainant

-versus- For: RTR in Physical Injury

With Damage to
Property
CYRUS ROLLUDA y GALICIA
JESSIE LORD D.R. LACANILAO
Respondent
x---------------------------------------------x

VERIFIED MOTION TO RELEASE IMPOUNDED VEHICLE

Comes now the undersigned, by himself and unto this Honorable Office, most
respectfully states:

That, now the undersigned is the lawful owner of a motor vehicle, which on the
____ day of ___________,2016 was impounded by police authorities and the filing of the
above entitled case against the above-named accused which is more particularly
described as follows:

MAKE/SERIES/TYPE :
ENGINE NO. :
CHASSIS NO. :
 FUEL :

That the release of the subject vehicle is of utmost importance having the
continued custody impedes the daily subsistence of the undersigned and it also needs
immediate repair caused by the incident.

Attached hereto are the following:

1. Affidavit of Undertaking
2. Certificate of Encumbrance
3. Pictures duly certified by Police Officer-on-case

WHEREFORE, it is most respectfully prayed that the said motor vehicle be

released in favor of the undersigned movant. Other relief under the premises is likewise
prayed for.

11 February 2016, Taytay, Rizal.

CARLOS A. QUIOGUE
Movant

REPUBLIC OF THE PHILIPPINES)

Pasig City )S.S.

AFFIDAVIT OF UNDERTAKING

I, SALOME BONIFACIO, of legal age, Filipino and with residence address at

No. 15 Phil-Am Road, Bo. Kapitolyo, Pasig City, after having been duly sworn to in
accordance to law, depose and say:

1. That I am the registered owner of the motor-vehicle described as follows:

MAKE : SUZUKI
CHASSIS NO. : SP-GP100UP-113985
MOTOR NO. : E102-113510
PLATE NO. : PV 9197

2. That on January 17, 2016, said motor vehicle was involved in the case of
Reckless Imprudence Resulting in Physical Injuries under I.S. No. XV-14-
INQ-16A-00043, assigned before Assistant City Prosecutor Eliezer G.
Arreola Jr., Prosecutor’s Office of Pasig City;

3. That said motor-vehicle was turned over to the EPD, Pasig City Police
Station, Vehicle Traffic Investigation Unit, C. Raymundo Avenue,
Caniogan, Pasig City, and there is the danger that it will deteriorate as it is
open to the elements and the same is needed in the business as the only source
of daily income;
 4. That as one of the conditions required for the release of the said vehicle, I
hereby undertake that I will present the same whenever I will be required to
do so;

5. That I am executing this Affidavit to attest to the truth of all the foregoing
facts and circumstances.

IN VIEW WHEREOF, I have hereunto set my hand this ___ day

of___________, 2016 at Pasig City.

SALOME BONIFACIO
Affiant

SUBSCRIBED AND SWORN to before me this ____ day of

_____________,2016 at Pasig City, representing her Valid ___________________.

Doc. No. ____

Page No. ____
Book No. ____
Series of 2016

REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
BRANCH 152
PASIG CITY

PEOPLE OF THE PHILIPPINES

Plaintiff,

-versus - CRIM. CASE NO. 131136

ORDER OF ARREST

FRANCISCO BARRERAZ
Accused
x---------------------------------------------x

MOTION FOR LIFT OF WARRANT

COMES NOW, the undersigned Witness, PO3 JONATHAN ACACHANG

TALIWAN, unto this Honorable Court, most respectfully states:

1. That on June 19, 2007, this Honorable Court issued an ORDER OF

ARREST which undersigned is hereby cited in contempt of Court for
allegedly unduly delaying the proceedings;
 2. That I have never intention to ignore to appear as witness in the above
entitled case, the truth is on January 2, 2006 I was re-assigned to
Tarlac City and I did not receive any notice of hearing;

3. That on May 19, 2016 when I am applying for clearance to NBI I was
informed by said office that “Non-appearance, RTC Pasig Branch
152, Case No. 131136”.

PRAYER

WHEREFORE, It is most respectfully prayed of this Honorable Court that the

Order of June 19, 2007 be considered and the forgoing MOTION FOR LIFT OF
WARRANT be approved.

Pasig City, 21 June 2016.

JONATHAN ACACHANG TALIWAN

Movant

Republic of the Philippines

Department of justice
National Prosecution Service
OFFICE OF THE CITY PROSECUTOR
Province of Pangasinan
City of Urdaneta

Jonathan I. Lopez,
Andrew H. Coroza,
George O. Tugade,
Cesar R. Dacanay,
Felipe C. Pelien,
Rhoda M. Delos Reyes,
Complainants,

-versus- NPS DOCKET NO.I-II-INV-16L-00450-51

For: Illegal Recruitment/ Estafa

Isagani Iscobido Jr.,

Joann Reyes,
Charina Tolentino
Ludivina Ancheta,
 Respondents,

z----------------------------------------------x

MOTION FOR RECONSIDERATION

Respondent, JO ANN LORENZO REYES, unto this Honorable

Prosecution Office, most respectfully move to reconsider the Resolution
dated February 28, 2017 of the above-entitled case, which was received on
March 23, 2017, on the following consideration;

1. A cursory examination of the records of the instant case shows that

the complaint was filed without the respondent having been given the
opportunity to present her evidence or defense during the Preliminary
Investigation. It is apparent that Movant-Respondent had no
participation whatsoever during the preliminary investigation as she
received no notices or that she was made aware that a Complaint had
been filed against her;

2. Verify, if only Respondent-Movant was given the opportunity to

submit her counter-affidavit before the Honorable Investigating her
innocence against the present Complaint;

3. It is axiomatic that preliminary investigation is a matter of right if not

waived and demanded within the opportune time. It must be
remembered that” in the context of preliminary investigation, the
right to due process of law entails the opportunity to be heard. It
serves to accord an opportunity for the presentation of the
respondents side with regard to the accusation xxx”. The essence of
due process is reasonable opportunity to be heard and submit
evidence in support of one’s defense”. (Kuizon v. Desierto, 406 Phil
611, 630 (2001).

4. The crime charged against herein respondent is so serious that if

allowed to run its course (despite the evidence against her is
fabricated) it might entail the respondent being drag in a long and
tedious litigation without due process of law;
 5. If allowed the right to preliminary investigation, herein respondent
shall prove that the evidence presented against her were all trumped
up and will not stand against a scrutinizing examination of an
unbiased mind;

6. In support of the instant Motion, Respondent respectfully maintains

that the said Respondent is consistent with her right to be afforded
the full opportunity to participate in the requested preliminary
investigation and present her evidence which arguably will become
useless if indicted as complained.

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed that this Honorable Prosecutor to give the Respondent full measure
of her right to preliminary investigation;

Other reliefs just and equitable in the circumstances are likewise

being prayed for.

Pasig City for Urdaneta City, Pangasinan, 7 April 2017.

JO ANN LORENZO REYES

Affiant

SUBCRIBED and SWORN to before me this

_____________at__________, Pasig City, affiant exhibiting her VIN ID No.
7403-0206D-C0773JLR20001-5.

Doc.No.______________;
Page No._____________;
Book No._____________’;
Series of 2017

CC:
Jonathan I. Lopez, No. 213 Bued, Binalonan
Andrew H. Coroza, Brgy. Casanesteban, Laoac
George O. Tugade, Sta. Maria, San Jacinto
Cesar R. Dacanay, No. 140 Mermer, Manaoag
Falipe C. Pelien, Brgy. Casanesteban, Laoac
 Rhoda M. Delos Reyes, No.765 Brgy. Camantiles, Urdaneta City,
Pangasinan
Hon. NOEL R. NERIZON
Assistant City Prosecutor
Office of the City Prosecutor
Province of Pangasinan
Urdanetaa City

JO ANN LORENZO REYES

No. 15 R.Castillo St., Brgy.
Kalawaan, Pasig City.

Republic of the Philippines

METROPOLITAN TRIAL COURT
National Capital Judicial Region
Branch 71, Pasig City

PEOPLE OF THE PHILIPPINES

Plaintiff M-PSG-16-01729-CR
For: Estafa under Art. 318
-versus- of the Revised Penal Code
(Other Deceits)
DONNABEL D. ROQUE,
Accused,

X___________________________ X

MOTION TO REVIVE ABOVEMENTIONED

CASE

COMES NOW, the undersigned Private Complainant, SALUDACION

OBNIAL, unto this Honorable Court, most respectfully revive the abovementioned case
against DONNABEL D. ROQUE, for the following considerations:

1. That the private Complainant, SALUDACION OBNIAL, filed a complaint

against DONNABEL D. ROQUE for Estafa Under Art. 318 of the Revised
Penal Code;
 2. That on July 19, 2018 the parties signed a COMPROMISE AGREEMENT
before the Honorable Judge HONORIO C. EBORA JR. as follows;

a) Accused agreed to pay to the private complainant the amount of ONE

HUNDRED THOUSAND PESOS (PHP100,000.00) as the
settlement to the REMAINING BALANCE on the civil aspect of this
case;

b) That the said amount is payable on or before AUGUST 20,2018 which

is the full and the final settlement of this case;

3. That the Honorable Judge the said Compromise Agreement is hereby

APPROVED and ADOPTED as judgment of this Court in so far as the civil
aspect of this case is concerned.

“ As prayed for the accused, through the Public Defender, without objection
from the private complainant and considering that the terms and conditions set
forth in the Compromise Agreement indicated that the obligation of the
e accused is to be satisfied within a period of one (1) month. Let the criminal
l aspect of this case be considered PROVISIONALLY DISMISSED with the
e express consent of the accused.”

“The Prosecution is reminded that it has only one (1) year from receipt of the
is judgment within which to move for the revival of this case.”

4. That the defendant never complied the payment as agreed up to the present,
she ignored and continues to ignore the verbal demand to pay the agreed
amount in accordance with the Compromise Agreement.

PRAYER

WHEREFORE , premises considered, it is most respectfully prayed that the

Honorable Court consider the foregoing MOTION TO REVIVE THE
ABOVEMENTIONED CASE and be approved.

Pasig City, 18 September, 2018.

SALUDACION OBNIAL
Complainant

COMFORME:

Prosec. JEROME T. VICTOR

City Prosecutor’s Office
CC: Ms. DONNABEL D. ROQUE
No. 3531 Elisco Road, Kalawaan
Pasig City