LFW3

TABLE OF CONTENTS 1. Criminal information for Murder 2. Criminal information for Homicide 3. Criminal information for Libel 4. Criminal information for BP Blg 22 5. Motion to quash quash criminal criminal complaint 6. Demurrer to Evidence 7. Petition for Bail 8. Motion to Reduce Bond/Bail 9. Motion to Suspend Suspend Proceedings Proceedings 10. Ex Parte Motion to set the case for pre-trial pre-trial conference conference

REPUBLIC OF THE PHILIPPINES National Capital Judicial Region REGIONAL TRIAL COURT City of Manila Branch 44 PEOPLE OF THE PHILIPPINES, Plaintiff,

-versus-

CRIMINAL CASE NO. 24242 For: Murder

EARL ESTACIO, Defendant. x-----------------------------------------------------x INFORMATION The undersigned Assistant City Prosecutor, upon sworn complaint originally filed by the offended party, accuses EARL ESTACIO of the crime of MURDER, committed as follows: That on or about January 15, 2017 in the city of Balanga, province of Bataan, Philippines, within the jurisdiction of this court, the said accused, did then and there, with malice aforestated and with deliberate intent to take the life of ANGELA SABAUPAN, wilfully, unlawfully, feloniously, suddenly and treacherously attack the latter with a knife, fist wounding him in the chest, and afterwards, when enfeebled and unable to defend himself, again in the stomach, both wounds being necessarily mortal, thereby causing the direct and immediate death of said ANGELA SABAUPAN. Contrary to law. Bataan, Philippines. April 2, 2017 (SGD) Earl Estacio Assistant City Prosecutor

Witnesses:

1. Ricky Flores 2. Beth Tamayo

Bail Recommended: P10,000

12 Del Monte Quezon City 222 Mayon Quezon City

CERTIFICATION I hereby certify that the preliminary investigation in this case has been conducted; I have examined the complaint and his witnesses and on the basis of their sworn statements and other evidence submitted before me there is reasonable ground to believe that the offense charged has been committed; the accused was informed of the complaint and was given an opportunity to submit controverting evidence and that the filing of this information was with the authority of the City Prosecutor.

Earl Estacio SUBSCRIBED AND SWORN to before me this 3rd day of MARCH 2017. Balanga, Bataan.

Randy David Administering officer

Republic of the Philipines National Capital Judicial Region REGIONAL TRIAL COURT Branch 22, Quezon City

PEOPLE OF THE PHILIPPINES, Plaintiff, -versus-

Criminal Case: 12345 For: Libel

Dr. Alicia Santos and Fr. Rolly Dela Vega, Accused. x - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -x INFORMATION The undersigned prosecutor accuses Dr. Alicia Santos and Fr. Rolly Dela Vega of the crime of libel, committed as follows: On or about 22 December 2015 in the City of Quezon, the accused, being then the editors in newspapers titled “Pilipinas Balita”, published in general circulation in the Philippines, voluntarily, feloniously and with the intention of attacking the honesty, virtue and reputation of ABA Educational System Inc. and for the purpose of exposing her to public hatred and ridicule, wrote in Issue No. 123 of said newspaper, an injurious and defamatory article which is in words as follows: “ Ang k apal naman ng mukha ng eskwelahang ito, itong si ABA Educational System, para magpatuloy sa pagtanggap ng mga estudyante at pagtanggap ng enrollees kahit na walang permit galling sa CHED. Hindi dapat pinapahintulutan itong eskwelahang ito na ipagpatuloy ang kanilang illegal na aktibidad sapagkat sinisira lamang nila ang buhay ng mga batang ito at binibigyan nila ng false hope ang kinabukasan nila.” The article in question had for its object to insinuate and made it understood, and interpreted by the public who read it, that the school referred to is no other that ABA Educational System Inc, and in this manner transmitting maliciously to the public the impression that the school has no permit to operate as an educational institution, with the purpose of destroying their reputation before the bar of public opinion. Contrary to Law.

Quezon City, 22 February 2016.

(SGD) Laurence Taguinod Assistant City Prosecutor

Witnesses:





Laurence Taguinod Subscribed and sworn to before me this 27 February 2016 in Quezon City.

Ricardo Puno Administering officer

REPUBLIC OF THE PHILIPPINES National Capital Judicial Region REGIONAL TRIAL COURT City of Manila Branch 44

PEOPLE OF THE PHILIPPINES, Plaintiff,

-versus-

CRIMINAL CASE NO. 24242 For: Homicide

EARL ESTACIO, Defendant. x-----------------------------------------------------x INFORMATION

The undersigned Assistant City Prosecutor, upon sworn complaint originally filed by the offended party, accuses EARL ESTACIO of the crime of MURDER, committed as follows: That on or about January 15, 2017 in the city of Balanga, province of Bataan, Philippines, within the jurisdiction of this court, the said accused, did then and there, with malice aforestated and with deliberate intent to take the life of NICU DELA MERCED, wilfully, unlawfully, feloniously, suddenly and treacherously attack the latter with a knife, fist wounding him in the chest, and afterwards, when enfeebled and unable to defend himself, again in the stomach, both wounds being necessarily mortal, thereby causing the direct and immediate death of said NICU DELA MERCED. Contrary to law. Bataan, April 2, 2017 (SGD) Earl Estacio Assistant City Prosecutor

Witnesses:





Earl Estacio SUBSCRIBED AND SWORN to before me this 3rd day of MARCH 2017 Balanga, Bataan.


REPUBLIC OF THE PHILIPPINES National Capital Judicial Region REGIONAL TRIAL COURT City of Manila Branch 44

YRIZ TAMIE MARIANO, Plaintiff,

-versus-

CRIMINAL CASE NO. 24242 For: Violation of B.P Blg 22

SPINEL DECLARO, Defendant. x-----------------------------------------------------x INFORMATION The undersigned Assistant City Prosecutor, upon sworn complaint originally filed by the offended party, accuses SPINEL DECLARO for having violated B.P. Blg 22, committed as follows: That on or about and during the period comprised between January 2, 2016 and March 2017 in the City of Manila, Philippines, within the jurisdiction of this court, the said accused, did then and there draw and issue Check 87232-22 and Check 238498-92 dated February 15, 2016, purportedly in payment of loan, which upon presentment for clearing/collection was dishonored by the drawee bank for the reason “Account Closed/Drawn against Insufficient Fund”, and which check the accused failed to replace with cash within 5 days from notice of dishonor. Contrary to law. Manila, 3 April 2017. (SGD) Earl Estacio Assistant City Prosecutor

Witnesses:




CERTIFICATION

I hereby certify that the preliminary investigation in this case has been conducted; I have examined the complaint and his witnesses and on the basis of their sworn statements and other evidence submitted before me there is reasonable ground to believe that the offense charged has been committed; the accused was informed of the complaint and was given an opportunity to submit controverting evidence and that the filing of this information was with the authority of the City Prosecutor.

Earl Estacio SUBSCRIBED AND SWORN to before me this 3rd day of MARCH 2017 Manila, Philippines.



-versus-


EARL ESTACIO, Defendant. x-----------------------------------------------------x MOTION TO QUASH Defendant thru counsel, and unto this Honorable Court, moves to quash the information filed against the said defendant on the following grounds: 1. That the criminal liability of the defendants has been extinguished; 2. That the defendant is in jeopardy of being convicted of the offense charged. ARGUMENTS a) That the criminal liability of the defendant has been extinguished. (Here state whether such extinction of criminal liability is founded on amnesty, pardon or marriage of the offender with the offended party in the cases where such pardon or marriage extinguishes criminal liability, prescription of offenses or the penalty, and the facts constituting such extinction) b) That the defendant is in jeopardy of being convicted of the offense charged. (Here state, among others, the crimes under which the name of the court in which he was in jeopardy, and the date and place of such jeopardy ) PRAYER WHEREFORE, in view of all the foregoing, it is respectfully prayed that the above-entitled information be quashed, and the defendant be discharged.

Other just and equitable reliefs are also prayed for. Manila for Las Pinas City, November 22, 2007. Demetrio Sandoval Counsel for Defendant 4th floor, Madrigal Tower, Madrigal Business Center, Alabang, Muntinlupa City Attorney’s Roll No. 2324 IBP 2324-01/03/08 Muntilupa PTR 4232-01/03/08 Muntilupa MCLE No. 23242-Nov. 17, 2007

REQUEST FOR AND NOTICE OF HEARING The Branch Clerk of Court Regional Trial Court Branch 24, Las Pinas City Please submit the foregoing Motion to the Court for its consideration and approval immediately upon receipt hereof and kindly include the same in the court’s calendar for hearing on November 29, 2007 at 8:30 in the morning. Demetrio Sandoval Counsel for Defendant

Atty. Conrado Manuel Counsel for Plaintiff 2176 Alabang-Zapote Road, Las Pinas City Please take notice that counsel has requested to be heard on November 28, 2007 at 8:30 in the morning. Demetrio Sandoval Counsel for Defendant EXPLANATION OF SERVICE Copy of the motion was served to the defendant by registered mail due to time and distance constraints, and for lack of the undersigned’s staff who can serve the same in person. Demetrio Sandoval CC: Atty. Conrado Manuel

Counsel for Plaintiff 2176 Alabang-Zapote Road, Las Pinas City


-versus-


EARL ESTACIO, Defendant. x-----------------------------------------------------x PETITION FOR BAIL Defendant, in the above-entitled case, thru counsel, unto this Honorable Court, respectfully states: 1. That the defendant is in custody for alleged commission of a capital offense; 2. That no bail has been recommended for his temporary release, on the assumption that the evidence of guilt is strong; 3. That the burden of showing that evidence of guilt is strong is on the prosecution, and unless this fact is satisfactorily shown, the defendant may be bailed at the court’s discretion. WHEREFOR, upon prior notice and hearing, it is respectfully prayed that the defendant be admitted to bail in such amount as this Honorable Court may fix. Manila, Philippines. 3 April 2017. Demetrio Sandoval Counsel for Defendant 4th floor, Madrigal Tower, Madrigal Business Center, Alabang, Muntinlupa City Attorney’s Roll No. 2324 IBP 2324-01/03/08 Muntilupa PTR 4232-01/03/08 Muntilupa MCLE No. 23242-Nov. 17, 2007

REQUEST FOR AND NOTICE OF HEARING

The Branch Clerk of Court Regional Trial Court Branch 24, Las Pinas City Please submit the foregoing Motion to the Court for its consideration and approval immediately upon receipt hereof and kindly include the same in the court’s calendar for hearing on November 29, 2007 at 8:30 in the morning. Demetrio Sandoval Counsel for Defendant

Atty. Conrado Manuel Counsel for Plaintiff 2176 Alabang-Zapote Road, Las Pinas City Please take notice that counsel has requested to be heard on November 28, 2007 at 8:30 in the morning. Demetrio Sandoval Counsel for Defendant EXPLANATION OF SERVICE Copy of the petition was served to the defendant by registered mail due to time and distance constraints, and for lack of the undersigned’s staff who can serve the same in person. Demetrio Sandoval CC: Atty. Conrado Manuel Counsel for Plaintiff 2176 Alabang-Zapote Road, Las Pinas City

Republic of the Philippines National Capital Judicial Region REGIONAL TRIAL COURT Branch 55, Quezon City

People of the Philippines, Plaintiff,

- Versus

-

Criminal Case: 1234 For: Libel

Dr. Alicia Santos and Fr. Rolly Dela Vega, Accused. x- - - - - - - - - - - - - - - - - - - - - - - - - - - - - -x

MOTION TO DEFER ARRAIGNMENT AND TO SUSPEND PROCEEDING The accused, thru counsel, states that: 1. The above entitled case is set for arraignment on June 12, 2016 at 9:00 in the morning. 2. The basis in filing the present information is the Resolution of the Office of the City Prosecutor of Quezon City dated February 27, 2016 and the order dated March 25, 2016. 3. On May 20, 2016, the accused filed a Petition for Review of the said resolution before the Department of Justice, and which petition for Review is still pending for resolution. 4. In order not to render the Petition for Review moot and academic, and in consonance with the provision of Sec. 11, Rule 116 of the Revised Rules of Criminal Procedure, accused respectfully moves that his arraignment schedule on June 12, 2016 be deferred or suspended and the proceedings of the above-entitled case be held in abeyance until the final resolution of the Petition for Review; 5. The present motion is filed not for the purpose of delaying early disposition of the case but to secure the accused hasty, malicious and oppressive prosecution, and to protect him from and open and public accusation of crime, expense and anxiety of a public trial and also to protect the State from useless and expensive trial.

Accordingly, premises considered, and in the interest of justice, it is respectfully asked that the arraignment of the accused set on June 12, 2016 and the proceedings in the present case be deferred and suspended until the final resolution by the Department of Justice of the Petition for Review. Other reliefs just and equitable are likewise prayed for. Quezon City, 26 May 2016.

Atty. Rodrigo Duterte Counsel for the Accused IBP 23232/Quezon City/ 1-1-11 Roll 2342432 PTR No. 232323/QC/1-1-11 MCLE Comp No. 23234

Notice and Copy Furnished:

Atty. Chato Cabigas Clerk of Court Regional Trial Court Branch 55, Quezon City Office of the City Prosecutor Quezon City Please be notified that the foregoing motion is set for hearing on June 2, 2005, Friday at 2:00 o’clock in the afternoon.

Rodrigo Duterte

EXPLANATION OF SERVICE The foregoing motion was not served personally to the Clerk of Court and for the private complainants and service by registered mail was resorted due to distance and lack of manpower and thereby rendering personal service inconvenient and impracticable.

Republic of the Philippines NATIONAL CAPITAL JUDICIAL REGION REGIONAL TRIAL COURT Branch 33, Cebu City Jose Martin Ramirez, Plaintiff,

- Versus

-

Civil case: 8945 For: Sum of Money with Damages

Spouses Rodrigo and Lourdes Eala Respondent. x--------------------------x EX PARTE MOTION TO SET THE CASE FOR PRE-TRIAL CONFERENCE

Plaintiff, thru counsel, states: 1. That the records of the case will show that the defendant had already filed his answer and no subsequent pleadings was filed; 2. That being the last pleading, the case should already be set for pre-trial conference pursuant to Sec. 1, of Rule 18 of the 1997 Rules of Civil Procedure. Accordingly, premises considered, it is requested to this Court that the above entitled case be set for pre-trial conference. Other reliefs just and equitable are likewise prayed for. February 26, 2016, Cebu City.

Atty. Jason B. Evangelista Counsel for Plaintiff Roll of Attorney 72727 IBP No. 88282/ 11-11-16 PTR No. 202020/ 11-11-16 MCLE No. 2424/ 05-30-14 Notice and Copy furnished: Atty. Peter Pan Counsel for Defendant

Suite 123 Linden Suites Tower Ortigas St., Pasig City The undersigned shall submit the foregoing motion for the Court’s resolution on 15 March 2016, Wednesday at 2:00 o’clock in the afternoon.

Jason B. Evangelista

EXPLANATION OF SERVICE The foregoing motion was not served personally to the Clerk of Court and for the private complainants and service by registered mail was resorted due to distance and lack of manpower and thereby rendering personal service inconvenient and impracticable.


-versus-


EARL ESTACIO, Defendant. x-----------------------------------------------------x MOTION TO REDUCE BAIL Accused, thru counsel, by way of a special appearance solely for this purpose, respectfully alleges: 1. That the accused has been charged with Murder and that the bail for his provisional release has been set at P50,000.00; 2. That the accused is a poor fellow of very limited means such that it is impossible for him to pay the full amount of his bond and is therefore constrained to request for a reduction of the amount of bail; 3. That it would be advantageous to everyone if he be given temporary liberty thereby allowing him to continue with his gainful employment and as head of the family with three dependents; 4. As such, accused appeals to the mercy and compassion of this Honorable Court and respectfully requests that the bail be reduced to P20,000.00; 5. That this motion for reduction of bail is being filed without prejudice to any other remedy which may be available to the accused and that the accused expressly reserves the right to question the legality of the issuance of the search warrant or his warrantless arrest if the circumstances would so warrant. WHEREFORE, accused respectfully prays that his bail be reduced to P20,000.00 Other relief just and equitable are likewise prayed for. Manila, Philippines. 3 April 2017.

Demetrio Sandoval Counsel for Defendant 4th floor, Madrigal Tower, Madrigal Business Center, Alabang, Muntinlupa City Attorney’s Roll No. 2324 IBP 2324-01/03/08 Muntilupa PTR 4232-01/03/08 Muntilupa MCLE No. 23242-Nov. 17, 2007

REQUEST FOR AND NOTICE OF HEARING The Branch Clerk of Court Regional Trial Court Branch 24, Las Pinas City Please submit the foregoing Motion to the Court for its consideration and approval immediately upon receipt hereof and kindly include the same in the court’s calendar for hearing on November 29, 2007 at 8:30 in the morning. Demetrio Sandoval Counsel for Defendant

Atty. Conrado Manuel Counsel for Plaintiff 2176 Alabang-Zapote Road, Las Pinas City Please take notice that counsel has requested to be heard on November 28, 2007 at 8:30 in the morning. Demetrio Sandoval Counsel for Defendant EXPLANATION OF SERVICE Copy of the motion was served to the defendant by registered mail due to time and distance constraints, and for lack of the undersigned’s staff who can serve the same in person. Demetrio Sandoval CC: Atty. Conrado Manuel Counsel for Plaintiff 2176 Alabang-Zapote Road, Las Pinas City

LFW3

Recommend Documents