Sample Motion for Production of Documents

Republic of the Philippines

National Capital Judicial Region
METROPOLITAN TRIAL COURT
Branch 67
Makati City

ABC CORPORATION,
Plaintiff,
- versus -

Civil Case No. 111222

RAYMOND CORPUZ MAPA,

Defendant.
x-------------------------------------------x

MOTION FOR PRODUCTION OF DOCUMENTS

PLAINTIFF, by counsel, moves for an order requiring defendant Raymond Corpuz Mapa:
1. To produce and permit plaintiff to inspect and to copy each of the following documents:
(Here, list the documents and describe each of them)
2. To produce and permit plaintiff to inspect and to photograph each of the following objects:
(Here, list the objects and describe each of them)
3. To permit plaintiff to enter (here describe property to be entered) and to inspect and photograph
(here describe the portion of the real property and the objects to be inspected and photographed)
Defendant has the possession, custody or control of each of the foregoing documents and objects and of
the above-mentioned real estate. Each of them constitutes or contains evidence relevant and material to the
matter involved in this action.
Makati City, Philippines. September 13, 2013.
ATTY. VX YZ
Counsel for Plaintiff

NOTICE OF HEARING
THE BRANCH CLERK OF COURT
MeTC - Branch 67
Makati City
Greetings!
Please submit the foregoing Motion to the Court for its consideration and approval immediately upon
receipt hereof and kindly include the same in the courts calendar for hearing on Friday, 27 September 2013 at
8:30 in the morning

VX YZ
Copy furnished:
ATTY. AB CD
Counsel for the Defendant
2233 Zamora Street, Pasay City
Please take notice that counsel has requested to be heard on Friday, 27 September 2013 at 8:30 in the
morning.
VX YZ

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Ejercito vs. Sandiganbayan, 509 SCRA 190 (2006)
All deposits of whatever nature with banks or banking institutions in thePhilippines including
investments in bonds issued by the Government of thePhilippines, its political subdivisions and
its instrumentalities, are hereby consideredas of an absolutely confidential nature and may not
be examined, inquired or lookedinto by any person, government official, bureau or office,
except upon writtenpermission of the depositor, or in cases of impeachment, or upon order of
acompetent court in cases of bribery or dereliction of duty of public officials, or incases where
the money deposited or invested is the subject matter of the litigation.
G.R. No. 185145

February 5, 2014

Adorio v. Hon. Bersamin,28 which held that

Requests by a party for the issuance of subpoenas do not require notice to other parties to the
action.1wphi1 No violation of due process results by such lack of notice since the other parties
would have ample opportunity to examine the witnesses and documents subpoenaed once they
are presented in court.
In Adorio, the request for subpoena duces tecum was sought against bank officials who were not parties to
the criminal case for violation of Batas Pambansa Blg. 22.