Republic of the Philippines Third Judicial Region REGIONAL TRIAL COURT City of San Fernando, Pampanga Branch 69
PEOPLE OF THE PHILIPPINES, Plaintiff ,
-versus-
CRIM. CASE NO !9"!##!$ FOR: T%&FT
JUDAS ISCARIOT,
Accused. '"""""""""""""""""""""'
MOTION FOR REINVESTIGATION
ACCUSED, through the undersigned counsel, to this %onorable Court, most respectfully state(
! That hat this this cas case )as )as fil filed by the the %ono %onorrable able *ss *sst Stat Statee City City Prose Prosecu cuttor )ithout the benefit of the accused ans)ering the charges against him+ That That )hi )hile le the the res resol olut utio ion n of the the %ono %onora rabl blee *sst *sst City City Pro Prose secu cuto torr stat states es that the accused )as unable to submit his counter-ailing e-idence despite numerous efforts efforts of the .ffice to inform him of the complaint complaint filed filed against against him and the scheduled scheduled preliminary in-estigation, ne-ertheless, the accused )as not really informed that there )as a case filed against him )ithout his fault /n fact, the information )as filed on June #!, and that the accused )as arrested only this 0ecember #!$ )hen the accused )ent to the police station to testify in a stabbing incident, ho)e-er, )hen found out by the policemen the name of the accused, that there )as a standing )arrant against him, the policemen instantly arrested the accused $ That That thi thiss mot motio ion n is anc ancho hore red d on the the fac fact, t, tha thatt accu accuse sed d in thi thiss case case has has a -ali -alid d defe defens nsee rang ranged ed agai agains nstt the the sole sole affi affidada-it it of the the comp compla lain inant ant )ith )ithout out any corresponding e-idence as to the o)nership of the said grinder sub1ect of this case e'cept the positi-e assertion of the pri-ate complainant+ 2 * per perso son n cann cannot ot be hel held d lia liabl blee for for the theft ft on the the prop proper erty ty belo belong ngin ing g to to them them /t is the pri-ate complainant complainant )ho s)indled the grandfather grandfather 3o)ner of the grinder4 of the accused )hen the pri-ate complainant failed to pay the agreed rental payment of P $#### per day The pri-ate complainant merely paid P#### for t)o"day use of the grinder, )hich is )hy they too5 bac5 the property they o)ned as the agreement is in a per day basis, the o)ner is entitled to the possession of the property e-ery ne't day unless the renter e'tends the same, or unless the renter pays the agreed amount /t is the pri-ate comp compla laina inant nt )ho )ho is oblig obligat ated ed to pay the the balan balance ce of P 2### 2#### # )hich )hich the the pripri-at atee complainant unla)fully refused to pay The The amo amoun untt of of the the grin grinde derr as as ref refle lect cted ed in the the rec recei eipt pt is only only P ,7 ,7## ### ## # contrary contrary to the allegation allegation of the false pretender"o) pretender"o)ner ner pri-ate complainant complainant )hich is P
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6,##### The receipt spea5s for itself that herein pri-ate complainant8s credibility is already in doubt 6 *ttached herein are the affida-it of the o)ner Peter riffin and the receipt of the grinder paid by Peter riffin )hich receipt is in his possession since January !:, #! until today WHEREFORE, premises considered, it is most respectfully prayed of this %onorable Court, that the foregoing motion be favorabl !ra"#$%.
City of San Fernando, Pampanga, 0ecember 2, #!$ 3Sgd4 *tty Rommelito Francisco & ;acarayo Co&"'$l for A((&'$% !$"69 Barrac5s Building, ;ari5ina /BP <. 7:!$":=!9=!"*C PTR <. 6699!$=!=!"*C Roll & &'empt 3*dmitted to the bar( *pril 6, #!4
NOTICE AND RE)UEST FOR HEARING T*$ +ra"(* Cl$r of Co&r# RTC BR*
Sir( Please calendar the foregoing ;otion for hearing on 0ecember !$, #!$ at !#($# o8cloc5 in the morning or at the earliest possible calendar of this %onorable Court, sans personal appearance of undersigned counsel
A##. Ro$l-#o Fra"(-'(o E. Ma(arao Co/ f&r"-'*$%:
*tty *ntonio *ntonio > Santos CIT0 PROSECUTOR City Prosecutor8s .ffice City of San Fernando
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