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Motion For Consolidation

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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Kai Pontanar
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254 views

Motion For Consolidation

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.

Uploaded by

Kai Pontanar
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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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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