Motion for Preliminary Investigation CRIMPRO 2014

Republic of the Philippines  Third Judicial Region REGIONAL TRIAL COURT City of San Fernando, Pampanga Branch 69 PEOPLE OF THE PHILIPPINES PHILIPPINES,, Complainant, - versus -

Criminal Case No. 482042 For: Violation For: Violation of RA 8353

NONGNONG DAYZON DAYZON,, Accused.  x --------------------------------------------- ------------------------------------- x OMNIBUS MOTION FOR PRELIMINARY INVESTIGATION W/ MOTION TO DEFER ARRAIGNMENT & TO SUSPEND PROCEEDINGS COMES NOW, the accused, through counsel, in the above entitled-cases unto this Honorable Court, most respectfully avers:

1.  That the instant case were file by virtue of an Inquest Proceedings conducted by Inquest Prosecutor Richard Galang on February 20, 2014; 2.  That the herein accused failed to submit any counter affidavit or any controverting evidence in his behalf;

3.  That the accused believes that if he h e will be given an opportunity to answer the charges against him, the resolution could have been different; 4.  That the accused most respectfully prays that a preliminary investigation for the instant cases be conducted before the Office of the Provincial Prosecutor;

5.  That this motion is not intended for delay but solely upon above-mentioned grounds.

WHEREFORE, premises considered, and in the interest of substantial  justice it is humbly prayed that the instant Motion be granted and the records of the instant case be transmitted to the Office of the Provincial Prosecutor for the conduct of Preliminary Investigation. Movant further prays for the deferment of the arraignment and for the suspension of proceedings pending resolution of preliminary investigation. City of San Fernando; 26 February 2014. (Sgd.) Atty. Rommelito Francisco E. Macarayo Counsel for Accused 13-69 Barracks Building, Marikina IBP NO. 87123-7/19/12-AC PTR NO. 669913/21/12-AC Roll No. 99998 MCLE Exempt (Admitted to the bar: April 6, 2012)

The Branch Clerk of Court RTC Branch 69 City of San Fernando Pampanga

Greetings! Please submit the foregoing motion for the kind consideration and approval of the Honorable Court upon receipt hereof. Many thanks!

Copy furnished: Office of the Provincial Prosecutor City of San Fernando, Pampanga

Comment: No Objection__________ Date: ___________