Republic of the Philippines

Department of Justice
OFFICE OF THE CITY PROSECUTOR
KALIBO CITY, AKLAN

EHRENFREL CHRISTOPHER C.
AZARRAGA,
Complainant, NPS Docket No: INV-
1900047
-Versus- For: ESTAFA

JOSE REYNALDO T. ONG, JILIAN MARIE

C. ONG, MA. CORAZON ABELA, JONATHAN
REYNALDO ONG, & RANDOLPH VINCENT
TIANGCO
Respondents,

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URGENT MOTION FOR EARLY RESOLUTION

Complainant, through counsel, to the Honorable Prosecutor,

respectfully states that:

1. The above-entitled case is a criminal action for ESTAFA

under the Revised Penal Code, which was filed on
______________.

2. That almost ____ years have passed but no action or

resolution has been doon; and

3. Thus, the undersigned is requesting for the early resolution

of the above entitled case so as not to frustrate the ends of
justice.

WHEREFORE, based on the premises presented, it is most

respectfully prayed of this Honorable Office that a Resolution be
rendered in this case based on the evidence presented.

Other just and equitable reliefs are likewise prayed for.

Respectfully submitted this ___ day of __________ 2020 in San

Juan City for Kalibo City, Aklan.

1
 AZARRAGA LAW OFFICE
3RD FLOOR, V.V. Soliven Bldg.
Greenhills, EDSA, San Juan City
Metro Manila
Tel: (02)87254095

By:

ATTY. EHREN CHRISTIAN SOLIVEN AZARRAGA

Roll No. 72731
IBP No. 113644/IBP Nat’l Office, Pasig
PTR No. 9508269/Quezon City
MCLE Compliance: Admitted to the Bar 2019

NOTICE OF HEARING

Honorable City Prosecutor

Office of the City Prosecutor

Greetings,

Please take notice that the undersigned will submit the

foregoing motion for the Honorable Office’s consideration
immediately upon receipt hereof without further oral arguments
and without presence of counsels/parties. Thank you.

ATTY. EHREN CHRISTIAN SOLIVEN AZARRAGA

EXPLANATION

Copies of the foregoing Motion were filed and served through

registered mail due to the distance of the offices involved and the lack
of liaison personnel.

ATTY. EHREN CHRISTIAN SOLIVEN AZARRAGA

Copy Furnished: