Republic of the Philippines
First Judicial Region
MUNICIPAL TRIAL COURT IN CITIES
Branch I
City of San Fernando, Province of La U.nion
PEOPLE OF THE PHILIPPINES CRIMINAL CASE NO.
44866
versus
For:
MARIE LOAN TRAN SALANGA, FALSIFICATION OF
PUBLIC
Accused.
DOCUMENT
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MANIFESTATION WITH MOTION FOR LEAVE
TO ALLOW ACCUSED TO TRAVEL ABROAD
ACCUSED, MARIE LOAN TRAN SALANGA, through the
undersigned counsel manifests and avers that:
1. Accused wishes to inform the Honorable Court that her
daughter, Sarifa T. Salanga who is based in Pasadena,
California, U. S. A. has a medical condition and is gravely ill, in
need of help from her mother;
2. Accused in this regard submitted to the undersigned counsel
her letter request with prayer to be allowed to travel to
the United States to attend personally to her ailing daughter
(ANNEX “A” & series) and cited among others the following:
2.a. Sarifa Salanga has cancer of the cervix (third
stage);
2.b. Her two (2) kidneys were already affected and now
undergoing regular dialysis;
2.c. Sarifa lives alone at Pasadena, California and her
medical condition was uncovered when her mother asked her
friend in California to check on her by suggesting to call 911 to
check on her at her residence;
1|Page Manifestation with Motion
2.d. 911 found out that she was actually bed-ridden and
had to rush her to the hospital to get proper medical attention
and she is now confined at Huntington Hospital, 100W
California Blvd., Pasadena CA 91105, U. S. A.;
2.e. Sarifa wanted to bear it all alone and did not
inform her mother as to her actual medical condition and does
not want to give consent to anyone to secure her medical
certificate;
2.f. Accused who is out on bail is well aware of her
pending falsification case filed against her by her other son,
Edmer Salanga now undergoing trial before this Honorable
Court, but she assures the Court that if granted her request to
travel, she will come back to face trial and prove her
innocence;
2.g. Accused also cited that she has all the reasons
to come back because of they are now in the final stage
in settling the intestate estate of her late husband,
Teodoro Salanga, Jr., to claim what belongs to her and to
her daughter Sarifa which the Regional Trial Court –
Branch 26 (Special Proceeding No. 3404) granted both
of them 1/3 share each of the properties to the estate of
the late Teodoro Salanga, Jr.;
2.h. Accused is asking for at least eight (8) months stay
in the U. S. and wishes to leave by August 15, 2024, or at a
time which would be granted by the Honorable Court, but she
prays that it be soon;
2.i. Accused is also describing the situation of her
daughter Sarifa as terminal and wishes to convey to the
Honorable Court of her resolve to be with her daughter even
for the last chance to see her personally and be with her while
she is still alive;
2.j. Accused also plans to take advantage of this travel
request (if granted) for her own medical examination and
procedure (if necessary) while in the U. S. on her “lipoma in
the interscapular area” and for her “hemorrhoids” (ANNEX
“B”); and
2.k. Accused also undertake to submit the soonest the
medical certificate of Sarifa for the reference of the Honorable
Court and while in the U. S., she will be staying at 1383 Locust
Street, Pasadena, CA, U. S. A.
PRAYER
2|Page Manifestation with Motion
WHEREFRORE, foregoing considered, herein accused
through the undersigned counsel humbly and respectfully prays to
the Honorable Court to take note of the foregoing manifestations
and MOVES for it to consider and grant her letter-request after
hearing and comments of the prosecution on the matter.
Other reliefs just and equitable under the premises are
likewise prayed for.
RESPECTFULLY SUBMITTED.
This 12th day of July 2024, San Juan, La Union for San
Fernando City, La Union, Philippines.
MOSUELA, GONZALES AND ASSOCIATES LAW OFFICES
Counsel for the Accused
Unit 1, San Juan LGU Multi-Purpose Center
Sta. Rosa de Lima Street, Ili Sur, San Juan, 2514 La Union
CP No. 0917 518 2410 – Email Address:
[email protected]By:
JAIME C. GONZALES, JR.
IBP Roll No. 68552, May 29, 2017
IBP No. 324698, December 4, 2023 (CY-2024)
PTR No. LU 6514046, January 03, 2024
MCLE Compliance No. VII-0012197, valid until April 14, 2025
NOTICE
THE BRANCH CLERK OF COURT
Municipal Trial Court in Cities – Branch 1
San Fernando City, La Union
G R E E T I N G S!
Kindly submit the foregoing Manifestation with Motion for
Leave to Allow Accused to Travel Abroad to the Honorable Court for
its consideration, evaluation, and approval and be set for hearing on
July 15, 2024 at 8:30 o’clock in the morning, or at a date and time
most convenient to the Court’s docket.
Thank you.
JAIME C. GONZALES,
JR.
3|Page Manifestation with Motion
COPY FURNISHED:
ATTY. FERDINAND A. FE
Fe Sapitula Lomboy Law Firm
2nd Floor, SKM Bldg., Quezon Avenue
Catbangen, San Fernando City, 2500 La Union
(also sent via personal service)
ACP MILDRED LLOBRERA
City Prosecutor’s Office, RTC Compound, Sevilla
San Fernando City, 2500 La Union
(also sent via personal service)
EXPLANATION
Copies of the foregoing Manifestation with Manifestation with
Motion for Leave to Allow Accused to Travel Abroad were served to
the Honorable Court and parties above mentioned via electronic
mail on July 12, 2024 and by LBC Courier service on July 13, 2024
due to the urgency of the matter.
JAIME C.
GONZALES, JR.
4|Page Manifestation with Motion
