Republic of the Philippines

DEPARTMENT OF JUSTICE
National Prosecution Service
Office of the Provincial Prosecution
Hall of Justice, Butuan City
*****

JANMAR SULHAYAN, NPS DOCKET NO. XIII-

02-
Complainant, INV-
14B-00014
FOR:
- versus -
Attempted Murder
EDDIE AMPIAWAN @ Kumander
Bawang,
Respondent.
x--------------------------/

OMNIBUS MOTION
[For Consolidation and Adoption]

Respondent, by the undersigned Law Office, most

respectfully avers THAT:

1. He was originally accused of the charged of

Murder for the death of Rolando Ambongan y Mansacuban
that transpired at about 7:20 in the evening of 31 January
2014, filed before this Honorable Office and docketed as
NPS Docket No. XIII-02-INV-14A-00008;

2. Respondent has already filed his Counter-Affidavit

in the aforementioned case;

3. Considering that the act complained of in the

instant case arose out of the same incident, involving the
same set of facts and the same respondent, the latter most
respectfully moves that the instant case be consolidated
with NPS Docket No. XIII-02-INV-14A-00008 and that his
Counter-Affidavit filed in such case be adopted as his
Counter-Affidavit in the instant case;
SULHAYAN vs. AMPIAWAN
Omnibus Motion
Page 2 of 3
x--------------------------/

4. This Omnibus Motion is filed in utmost good faith

and to obviate the possibility of conflicting resolutions
arising out of the same incident.
MOST RESPECTFULLY SUBMITTED.
Butuan City (for Surigao City), Philippines,
17 March 2014.

HENRY C. FILOTEO
Counsel for the Respondent
Roll No. 44949
PTR No. 0402903, 1/04/12, Butuan City
IBP Lifetime No. 06979
MCLE Compliance No. III-0001453, 12-17-08
RESERVA•FILOTEO LAW OFFICE
2nd Floor, PS Arcade, Deofavente Bldg.
J. Rosales Avenue, Butuan City

NOTICE OF HEARING

HON. CYRIL VIVA

Assistant Provincial Prosecutor
Hall of Justice, Butuan City

JANMAR SULHAYAN
Complainant
Buenavista, Agusan del Norte

Greetings:

Please take notice that on Friday, 21 March 2014 at 2:00

o’clock in the afternoon or thereabouts, or as soon as this
may be calendared for hearing, the undersigned counsel
will present the foregoing Motion for kind consideration and
approval of this Honorable Investigating Prosecutor.
SULHAYAN vs. AMPIAWAN
Omnibus Motion
Page 3 of 3
x--------------------------/

HENRY C.
FILOTEO

COPIES FURNISHED

1. JANMAR SULHAYAN
Complainant
Balatakan, Brgy. Guinabsan
Buenavista, Agusan del Norte
Registry Receipt No. : ____________________
Date : ____________________

EXPLANATION

Copies of this Omnibus Motion was sent to complainant via

registered mail due to distance.

HENRY C.
FILOTEO