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Regional Trial Cocurt Branch 31: Motion For Reconsideration

The accused, Nathaniel S. Guillermo, filed a Motion for Reconsideration of a court order directing the Philippine National Police to transfer him to the Bureau of Jail Management Penology for documentation. The accused argues that the PNP detention facility in Diffun, Quirino is more convenient as it is closer to his family who can provide his medical and other needs. He also claims his security is better ensured at the PNP facility. Therefore, the accused requests that the court recall its order and allow him to remain detained at the PNP facility in Diffun, Quirino while his case is pending.

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AttyKaren Baldonado-Guillermo
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148 views

Regional Trial Cocurt Branch 31: Motion For Reconsideration

The accused, Nathaniel S. Guillermo, filed a Motion for Reconsideration of a court order directing the Philippine National Police to transfer him to the Bureau of Jail Management Penology for documentation. The accused argues that the PNP detention facility in Diffun, Quirino is more convenient as it is closer to his family who can provide his medical and other needs. He also claims his security is better ensured at the PNP facility. Therefore, the accused requests that the court recall its order and allow him to remain detained at the PNP facility in Diffun, Quirino while his case is pending.

Uploaded by

AttyKaren Baldonado-Guillermo
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

REGIONAL TRIAL COCURT


Second Judicial Region
Branch 31
Cabarroguis, Quirino

PEOPLE OF THE PHILIPPINES,


Plaintiff, CRIM. CASE NO. 3918
FOR: VIOLATION OF SEC. 11
ART. II OF R.A. 9165
-versus-

NATHANIEL S. GUILLERMO,
Accused.
x--------------------------------------x

MOTION FOR RECONSIDERATION


(to the Order dated 8 October 2019)

Accused, through the undersigned counsel and unto the


Honorable Court, respectfully states:

1. That on 8 October 2019, the Honorable Court an Order


directing the Philippine National Police (PNP) Diffun, Quirino to
bring the living body of the accused to the Bureau Jail Management
Penology for documentation purposes;

2. That to be candid, the accused desire to stay in detentions for


the meantime while the case is pending in the detention facility of the
PNP, Diffun, Quirino. The detention facility of the PNP Diffun,
Quirino is more convenient to him as his family is always available
anytime to provide his medical and basic needs. There are
establishments and institutions nearby to cater the medical needs of
the accuse;

3. That moreover, his security is better looked upon inside the


PNP Diffun, Quirino detention facility;

PRAYER

Wherefore, it is most respectfully prayed tha the Order


directing the delivery of the living body of the accused to the BJMP

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be recalled and order the detention of the accused with the PNP
Diffun, Quirino while the case is pending.

Such other reliefs as are just and equitable are prayed for in the
premises.

Cabarroguis, Quirino. 16th October 2019.

Atty. MA. KAREN A. BALDONADO-GUILLERMO


Counsel of the Accused

CC:

Office of the Provincial Prosecutor


Cabarroguis, Quirino

The Clerk of Court


BRANCH 31
Regional Trial Court
Cabarroguis, Quirino

Please inform the Honorable Court that this motion is


submitted for resolutions without further oral arguments.

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