1

REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION
METROPOLITAN TRIAL COURT
City of Manila
Branch 21
PEOPLE OF THE PHILIPPINES,
Plaintiff,
- Versus -

Criminal Case No. 468396-CR

For: Falsification of Public

Document
ACMAD ALAMADA,
Accused.
X

MOTION

(To Produce the Original Copy of the

Questioned Assignment of Rights)
COMES NOW, the Private Complainant, in the
above entitled case, by and through the Undersigned
Counsel and unto this Honorable Court, most
respectfully avers:
1. That the subject Document in the case is the
questioned alleged Deed of Assignment wherein the
signature of the Private Complainant was falsified;
2. That the Original Copy of the subject
Questioned Document, the Assignment of Right, is in
the possession, custody and control of the Accused
and/or the defense;
3. That the examination of the subject
document, the said Assignment of Right by the
National Bureau of Investigation (NBI) is very
necessary, vital and paramount in the case, thus,
there is an imperative necessity for the accused and /
or the defense to produce the Original Copy of said
Assignment of Right for the same to be referred to
the NBI or NBI Handwriting Expert for its examination.
P

WHEREFORE, premises considered, it is most

respectfully prayed of this Honorable Court that:

a.
This Motion be given its due weight and
credence; and
b. The accused and / or the Defense be ordered
or be directed to produce the Original Copy of the
subject Questioned Document or the Assignment of
Right in Court for the same to be referred to the
National Bureau of Investigation or NBI Handwriting
Export for examination.
Private Complainant prays for other reliefs and
remedies just and equitable under the premises.
City of Manila, April 4, 2014.

ATTY. LEOPOLDO P. DELA ROSA

PRIVATE PROSECUTOR
Suite 307 CCI Building
1091 Concepcion Street
Ermita, Manila
PTR No. No. 1476454 / 1-18-2013
IBP No. 906971 / 11-28-2012
Roll No. 28195
MCLE Compliance No. IV-0020667
June 13, 2013

NOTICE
The Branch Clerk of Court
MTC, Branch 21
City of Manila
Hon. ACP ROSE MACRINA Q. TAN-CHUA CHENG
Office of the City Prosecutor
Manila City Hall
City of Manila
ATTY. ABDUL A. BASAR
Suite 202 Edsol Seyer Building
1175 A. Mabini Street
Ermita, Manila

Greetings

Please take notice that Undersigned will submit the

foregoing Motion for the kind consideration and approval of
the Honorable Court on April _____ , 2014 at ______________.

ATTY. LEOPOLDO P. DELA ROSA

With my express conformity:

Hon. ACP ROSE MACRINA Q. TAN-CHUA CHENG

EXPLANATION
This is to certify as an Officer of the Court that a copy of this Motion
was served, not by personal service but by registered mail as herein-below
indicated by reason of time, distance, lack of manpower and urgency.

ATTY. LEOPOLDO P. DELA ROSA

Copy furnished:
ATTY. ABDUL A. BASAR
Suite 202 Edsol Seyer Building
1175 A. Mabini Street
Ermita, Manila
OFFICE OF THE CITY PROSECUTOR
City of Manila