Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

10th Judicial Region
Branch 1
Cagayan de Oro City
-o0o-

PEOPLE OF THE CRIM. CASE NO. M16-

PHILIPPINES, 10-3368
Plaintiff,

-versus-

ERLINDA P. GAVIA and For: Violation of B.P.

GERALDINE S. LANGCATAN 22
Accused.
x----------------------/

MOTION TO REVIVE CRIMINAL CASE

COMES NOW, Private complainant, through the

undersigned counsel under the direct supervision and control
of the Honorable Public Prosecutor, and unto this Honorable
Court, avers that:

1. This instant case was ordered archived by this Honorable

Court through its Order dated January 9, 2017.

2. That in the same Order, the private complainant was

directed to provide this Honorable Court with the correct
address of the accused for the revival of this instant criminal
case;

3. Upon receipt of the afore-mentioned order, private

complainant directed its employees to determine the true
and correct address of the accused. And as such, it was
found out that accused Geraldine S. Langcatan already has a
new address and is a now a resident of a different locality;

4. Thusly, in compliance with the Order dated January 9, 2017

of this Honorable Court, private complainant hereby submits
the new address of accused Geraldine S. Langcatan, thus:
Block 5 Lot 49, Paglaum, Phase 1, Casisang,
Malaybalay City;

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5. Furthermore, considering that private complainant is
conversant with the address of the accused Geraldine S.
Langcatan both as to the street and direction, private
complainant sincerely believes that the service of any Order
of this Honorable Court addressed to the above-named
accused may be better effected if the service thereof will be
assisted by the private complainant.

PRAYER

WHEREFORE, premises considered, it is most

respectfully prayed unto this Honorable Court that an
ORDER be issued:

1. REVIVING this instant criminal case;

2. DIRECTING the issuance of a new Order to

the accused Geraldine S. Langcatan with the above-
provided address;

3. ALLOWING and/or AUTHORIZING private

complainant to ASSIST in the service of the new
Order.

Other reliefs just and equitable under the

circumstances are likewise prayed for.

Cagayan de Oro City. February 2, 2017.

ARUBIO CADAVOS BARSAGA Law Office

2/F FICCO Bldg., Tiano Bros. St. cor. Recto Ave.,
Cagayan de Oro City
Counsel for the Private Complainant
For the Office

By:

ATTY. DELBERT JOHN Z. BARSAGA

PTR No. 3346536 A (01-04-2017) for 2017
IBP No. 1059512 (01-05-2017) Misamis Oriental for 2017
Roll No. 65365 / TIN No. 488-163-997
MCLE Compliance: Admitted to the Bar 2016

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 Tel No. (088)880-0970 / Mobile No. 0910-5183411

With my conformity:

Hon. Omar-Sharief M. Naga

Office of the City Prosecutor
City Hall, Cagayan de Oro City

NOTICE OF HEARING

Hon. Omar-Sharief M. Geraldine S. Langcatan

Naga Block 5 Lot 49, Paglaum,
Office of the City Phase 1, Casisang,
Malaybalay City.
Prosecutor
City Hall, Cagayan de Oro
City

Please be informed that the foregoing Motion is set to

be heard on February 8, 2017 (Wednesday) at 8:30 in the
morning for the resolution and approval of the Honorable
Court or as soon as counsel may be heard.

Hon. Branch Clerk of Court

MTC-Branch 1
Cagayan de Oro City

Please kindly set the foregoing Motion to be heard on

February 8, 2017 (Wednesday) at 8:30 in the morning for the
resolution and approval of the Honorable Court or as soon as
counsel may be heard.

PROOF OF SERVICE / EXPLANATION

(Pursuant to Section 11, Rule13 of the 1997 Rules of Civil
Procedure)

I hereby certify that a copy of the foregoing Motion is

served thru personal service to:

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Hon. Omar-Sharief M. Naga Received by: _________
Office of the City Prosecutor Date: _______________
City Hall, Cagayan de Oro City

And thru registered mail in view of the distance and

lack of personnel to personally the same, to:

Geraldine S. Langcatan Registry Receipt No.

Block 5 Lot 49, Paglaum, _____
Phase 1, Casisang, Date: __________________
Malaybalay City.

ATTY. DELBERT JOHN Z. BARSAGA