REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
PARANAQUE CITY
BRANCH 194
MA. TERESA CECILIA PONCE
Petitioner,
105
-versus-

CIVIL CASE NO. 15FOR: Petition for Protection

Order
ONOFRE PONCE JR.
Respondent.
x------------------------------------------x

MOTION TO MARK PROVISIONAL EXHIBITS

RESPONDENT, through the undersigned counsel unto
this Honorable Court, respectfully alleged that:
1. On September 23, 2015, the Court provisionally
marked the Exhibit of the Respondent Exhibit 1 and Exhibit
1-A, E Pass Statement of Account dated 05-26-2015 on the
ground that the opposing counsel refuses to stipulate that
the copy thereof was the faithful reproduction of the original
reasoning that the person who signed the same did not
disclose his/her authority, said Exhibits is hereto attached as
ANNEX A and A-1 and made integral part hereof;
2. On September 23, 2015, the Court provisionally
marked the Exhibit of the Respondent Exhibit 1-B Certified
True Copy of BEST: Bancassurance Empowered Sales Training
dated November 3-5 2014 on the ground that the opposing
counsel refuses to stipulate that the copy thereof was the
faithful reproduction of the original, said Exhibits is hereto
attached as ANNEX B;
WHEREFORE, the respondent respectfully moves that
the provisionally marked Exhibits be marked permanently.
Such other reliefs and remedies as may be deemed just
and equitable are likewise prayed for.

RESPECTFULLY SUBMITTED. Makati City for Paranaque City.

24 September 2015.

LUSTRE SANTOS & ASSOCIATES LAW OFFICE

Counsel for the Respondent
9th Floor LPL Suites, 112 Legaspi Street
Legaspi Village Makati City

By:
BERNADETTE M. BAYAD
PTR No. 5015316, 8/17/2015, Makati
IBP No. 1007153, Isabela
Attorneys Roll No. 64856
Exempted form MCLE- Admitted to
The Philippine Bar April 29, 2015

COPY FURNISHED:

MA. TERESA CECILIA PONCE

Petitioner
416 Lilac Bldg., Siena Park Residences
Brgy. Sun Valley, Bicutan, Paranaque City
ATTY. MARNI ROSE D. ZATARAIN
Counsel for Petitioner
NAVARRO LAW OFFICES
2710 One Corporate Centre, Meralco Avenue
Cor. Julia Vargas Avenue, Ortigas Center, Pasig City

NOTICE OF HEARING
The Branch Clerk of Court
Branch 194

RTC, Paranaque City

Navarro Law Offices
GREETINGS!
Please take notice that the undersigned counsel is
submitting the foregoing motion for the Honorable Courts
kind approval and consideration immediately upon filing,
without need of counsels presence or further arguments.

BERNADETTE M. BAYAD

EXPLANATION: In accordance with Section 11, Rule 13 of the

New Rules on Civil Procedure, copies of the foregoing Motion
were served by way of [ ] LBC [ ] Registered Mail to the other
parties due to lack of personnel to undertake personal service.

BERNADETTE M. BAYAD