Republic of the Philippines

OFFICE OF THE CITY PROSECUTOR

Hall of Justice
Butuan City

ZIANDRO LEE, proprietor NPS NO.________________

of XXXES Mechanical and
Industrial Service,
Complainant,
FOR:

ESTAFA through Issuance

-versus- of Bouncing Checks under
Article 315, section 2(d) of
the Revised Penal Code
and Violation of B.P. 22;
ENGR. ROBERT TAAL,
proprietor of Sabugaa
Builders and Services,
Respondent.
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VERIFIED MOTION TO
ADMIT EVIDENCE

COMES NOW private complainant by counsel, unto the

Honorable Office, most respectfully enter his appearance as counsel
for private complainant, and in amplification thereto, most
respectfully avers:
1. That December 5, 2016, the undersigned counsel advised
complainant and his witness to proceed to the Office of the
City Prosecutor in order to have their respective affidavits
be subscribed and sworn with a clear instruction to return
to him the already-subscribed affidavits;

2. That the intention of the undersigned counsel was to

attach thereafter the copies of the rubber checks
respondent issued which are the subject of this case;

3. Unfortunately, private complainant might have

misunderstood the undersigned counsel’s instruction in
such a way that instead of returning to him the said
subscribed affidavits, private complainant had filed the
same for docketing, sans the copies of the rubber checks
and the Demand Letter;

4. That the undersigned counsel thinks and is apprehensive

that without the handling prosecutor seeing the rubber
checks and the demand letter, this complaint might not be
able to withstand scrutiny and instead be dismissed for
lack of evidence to support a finding of probable cause.
Hence, this verified motion.

PRAYER
 WHEREFORE, premises considered, it is respectfully prayed
that attached clearer copies of the Bounced Checks and Demand Letter
be admitted.
Such other reliefs and remedies just and equitable are likewise
prayed for.

Respectfully submitted, Cagayan de Oro City, December 11,

2016.