Republic of the Philippines

Provincial Prosecution Office

Camarines Sur
Hall of Justice, Naga City

SALVE LACOSTE,
Complainant, NPS-V-05-INV-16F-1062 (ESTAFA)
NPS-V-05-INV-16F-10623
(FALSIFICATION)
NPS-V-05-INV-16F-10623 (USE OF
FALSIFIED DOCUMENTS)
-versus-

HAZEL BRAZAL, JOSEPHINE ARMENDI

MARIAN ABIGAIL NUNEZ, JANE BLANCO
AND NESTOR OSCILLADA
Respondents
x- - - - - - - - - - - - - - - - - - - - - -x

MOTION FOR RECONSIDERATION

(OF THE RESOLUTION DATED JUNE 23, 2016)

Complainant-Movant Salve Lacoste, by herself unto this Honorable

Office, most respectfully sets forth, that:

TIMELINESS OF THIS ACTION

1) Respondent-Movant was received a copy of the Resolution in the above-

entitled case on July 25, 2016; Thus, she has until August 9, 2016 within
which to file this Motion for Reconsideration;

GROUNDS RELIED

2) In the Resolution, the Honorable Investigating Prosecutor DISMISSED the

complaints in the above-entitled cases on the following grounds:

a) Lack of a sworn Testimony or Certification from Atty. Glen Perillo;

b) Lack of Sworn Statement coming from Glecy Garcia;
c) There is doubt as to the jurisdiction considering the facts that the
documents subject of this case were notarized in Pili, Camarines Sur,
and the money was given at BDO, Nabua;

------------------
Page 1 of 3
 COMPLIANCE

3) The undersigned in acquiescence to such lack, respectfully submits the

following documents and arguments:

a) The Undersigned on July 5, 2016 submitted and was received by the

City Prosecution a Certification issued by Atty. Glen Perillo indicating
that the TCT relied upon by complainant was a fake one, hereto
attached as Annex “A”

b) Affidavit of Josephine Armendi dated June 3, 2016 she voluntarily

executed before Assistant City Prosecutor Herman M. Cledera, stating
that she was enticed by Marian Abigail Nunez to pretend to be Glecy
Garcia and was issued fake BIR Tin Card and Driver’s License to
transact the sale of the house and lot of the real Glecy Garcia,
attached as Annex “B”

c) The real Glecy Garcia was approached by undersigned. The latter

refused to execute a sworn statement because she had already sold the
house and lot to another person and has nothing to do with the
instant case. Undersigned cannot by herself force Glecy Garcia to
execute a sworn statement. That is her constitutional right. This leaves
undersigned with a predicament in such absence;

d) As to the issue of Jurisdiction, it is respectfully submitted that Naga

City Prosecution Office has jurisdiction in the above entitled case on
the following grounds:

i) The location of the house and lot is in Naga City;

ii) The deception/ false pretenses and enticements were made in Naga
City;
iii) The Fake Title was shown to undersigned at Camella Homes, Naga
City, that is why undersigned agreed to shell out the loan;
iv) Had the fake title not shown to undersigned in Naga City she
would not have approved of the loan;
v) There was already a meeting of minds in Naga City, hence the
Contract of Loan was already consummated albeit not perfected.
Hence an essential element in the commission of the offense of
falsification, use of falsified documents and estafa exists in Naga
City;

------------------
Page 2 of 3
 CONCLUSION
4) In summary, the above disquisition and documents submitted if taken
into consideration by this Honorable Office clearly shows that probable
cause for the above-offenses exists against above named respondents .

PRAYER

WHEREFORE, it is most respectfully prayed of this Honorable Office

that the Resolution of this Honorable Office dismissing the above-entitled
cases be reversed and a new resolution be issued finding probable cause
and recommending the filing of Informations in Court.

July ___ , 2016, Naga City, Philippines.

SALVE LACOSTE
Complainant-Movant

VERIFICATION

I, Salve Lacoste, of legal age, after having been duly sworn in accordance
with law, depose and state that:

1. I am an the Complainant-movant in the above-entitled case; I have

caused the preparation of the foregoing and I have read the contents
thereof and the facts stated therein are true and correct of my personal
knowledge and/or on the basis of copies of documents and records in my
possession;

SALVE LACOSTE
Affiant

SUBSCRIBED AND SWORN to before me this _______________, in the

City of Naga, Philippines.

------------------
Page 3 of 3