Republic of the Philippines

REGIONAL TRIAL COURT

5th Judicial Region
Naga City, Camarines Sur
Branch _____

NENITA O. SIGUENZA,
Plaintiff,
Civil Case No. ______
-versus- For: Collection of Sum of Money

NENETTE MAE O. SIGUENZA,

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

MOTION FOR NEW TRIAL

DEFENDANT, by the undersigned counsel, respectfully avers

that:

1. Defendant received a copy of the decision on September 10,

2019, which was obtained by plaintiff through FRAUD;

2. A new evidence was discovered, which he could not, with

reasonable diligence have discovered and produced at the
trial and if considered would alter the outcome of the case;

3. The above-mentioned discovered evidence consists of two

letters stating that the said obligation has been paid
including the interest set forth in the first promissory note
signed;

4. The affidavits of Imelda Malonda and Yolanda Baduria are

hereto attached as Annexes “A” and “B” to substantiate the
aforementioned newly-discovered evidence.

WHEREFORE, premises considered, it is most respectfully

prayed that the decision of this Honorable Court be set aside and a
new trial granted.
 Such other relief and remedies as may be deemed just and
equitable under the premises are likewise prayed for.

Naga City, Camarines Sur, Philippines, September 25, 2019.

APRIL ROSE A. SIGUENZA

Counsel for the Defendant
Attorney’s Roll No. 12345
IBP No. 123456, January 1, 2019/ Camarines Sur
PTR No. 7654321, January 1, 2019/ Naga City
MCLE Comp. No. IV-0001234, Valid until March 2, 2019
2nd Floor, Five Point Bldg., Caceres St.,
Corner Mayon Avenue, Tinago, Naga City
Telephone Number: (054) 123-456
Fax Number: (054) 231-4322

NOTICE OF HEARING

ATTY. EGMEDIO C. BLACER

Counsel for the Plaintiff
2nd Floor, Palma-Afable Bldg.,
Panganiban Drive, Naga City

Greetings:

Please take Notice that the foregoing Motion will be submitted

for the consideration and approval of the Honorable Court on
September 30, 2019 at 8:30 o’clock in the morning with counsel
waiving his appearance thereat.

APRIL ROSE A. SIGUENZA

Counsel for the Defendant