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Motion To Reopen Preliminary Investigation

The respondents Gerardo Joson and Annabel Roca Joson filed an omnibus motion to reopen the preliminary investigation. They claim they only received the subpoena summoning them to the investigation on February 22, 2021, well after the scheduled dates of January 25 and February 1, 2021. They provided a certification from the Post Master General of Manila confirming the late receipt of the summons. As they did not intend to ignore the summons, they request the investigation be reopened to allow them to respond to the criminal allegations against them.

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Grebert Karl Jennelyn Sison
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7K views3 pages

Motion To Reopen Preliminary Investigation

The respondents Gerardo Joson and Annabel Roca Joson filed an omnibus motion to reopen the preliminary investigation. They claim they only received the subpoena summoning them to the investigation on February 22, 2021, well after the scheduled dates of January 25 and February 1, 2021. They provided a certification from the Post Master General of Manila confirming the late receipt of the summons. As they did not intend to ignore the summons, they request the investigation be reopened to allow them to respond to the criminal allegations against them.

Uploaded by

Grebert Karl Jennelyn Sison
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

OFFICE OF THE CITY PROSECUTOR


Manila

Hon. CHRISTIAN B. CABRERA


Assistant City Prosecutor
Rm. 312M, 3rd Floor Manila City Hall

MARIA CORAZON JOSON,


Complainant,
I.S No. XV-07-INV-21A-00037
- versus - For: False Allegation and
Defaming Character

GERARDO JOSON,
ANNABEL ROCA JOSON, et. al.,
Respondent/s.
x ------------------------------------------ x

OMNIBUS MOTION FOR REOPENING THE


PRELIMINARY INVESTIGATION

COMES NOW, the respondents spouses GERARDO JOSON and


ANNABEL ROCA JOSON, unto this Honorable Office and most
respectfully avers:

1. This Office issued a Subpoena dated 14 January 2021 with


registry receipt number RE 458 018 010 ZZ directing both the
respondents to appear for preliminary investigation on 25 January 2021
and 01 February 2021, both at 10:00 AM respectively;

2. That both herein respondents only received the subpoena on


22 February 2021, or long after the scheduled settings for this case;

3. That on 23 February 2021, respondent GERARDO JOSON


immediately went to the Office of this Honorable Prosecutor and
informed the staff of this Honorable Prosecutor of the fact that their
failure to appear on the scheduled hearing was solely due to the late
receipt of the subpoena and that they had no intention of ignoring the
charge;

4. That the respondent was then advised to seek the advise of a


lawyer on the possible remedies that are available under the
circumstances;
Page 2 of 3
MOTION TO REOPEN PRELIMINARY INVESTIGATION
I.S No. XV-07-INV-21A-00037
Joson vs. Joson, et. al.

x-----------------------x

5. That pursuant to the advise, herein respondent requested for


a certification (Annex “A”) from the Post Master General of Manila to
unquestionably determine the date of respondents’ actual receipt of the
summons. Said Certification was issued only on 17 March 2021;

6. That, considering the foregoing, both accused manifest that


they do not have any intention of ignoring the summons of this
Honorable Office and most respectfully submit that they should be
given an opportunity to receive the complaint-affidavit and answer the
charges against them. In this connection, respondents most respectfully
request that a re-opening of the preliminary investigation for the instant
case be conducted; and

7. That this motion is not intended for delay but solely upon
above-mentioned grounds.

PRAYER

WHEREFORE, premises considered, and in the interest of


substantial justice it is humbly prayed that the instant Motion be granted
and additional settings for preliminary investigation be given to afford
both respondents an opportunity to refute the criminal allegations against
them.

Other reliefs be granted as shall be deemed just and equitable in the


premises

24 March 2021 in the City of Manila.

RESPECTFULLY SUBMITTED.

______________________________ ______________________________
GERARDO JOSON ANNABEL ROCA JOSON
Respondent Respondent
Evekal Townhouse Condominium Evekal Townhouse Condominium
1604 Pedro Gil Street 1604 Pedro Gil Street
Paco, Manila 1007 Paco, Manila 1007

Copy furnished: (by registered mail)

MARIA CORAZON JOSON


Complainant
Manansala Tower
Page 3 of 3
MOTION TO REOPEN PRELIMINARY INVESTIGATION
I.S No. XV-07-INV-21A-00037
Joson vs. Joson, et. al.

x-----------------------x

1211 Hidalgo Drive cor. Estrella


Rockwell, 1200 Makati City

EXPLANATION

Copies of the foregoing Motion were served to the concerned


parties, and filed with this Honorable Office, by registered mail due to
constraints of distance, time, and lack of personnel to effect personal
delivery.

GERARDO JOSON ANNABEL ROCA JOSON

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