This document is a motion to withdraw a complaint of frustrated murder and replace it with a complaint of murder. The original complaint was filed after the complainant's son suffered serious head injuries from an altercation while playing basketball. However, the son subsequently died from his injuries. Therefore, the complainant is requesting to withdraw the frustrated murder complaint and replace it with a complaint of murder against the same respondents.
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Motion To Withdraw Complaint
This document is a motion to withdraw a complaint of frustrated murder and replace it with a complaint of murder. The original complaint was filed after the complainant's son suffered serious head injuries from an altercation while playing basketball. However, the son subsequently died from his injuries. Therefore, the complainant is requesting to withdraw the frustrated murder complaint and replace it with a complaint of murder against the same respondents.
BALBA to the Honorable City Prosecutor’s Office, most respectfully avers that; 1. On February 19, 2020 a complaint for Frustrated Murder was filed by the undersigned against ARIS GARCIA and TROY CABANGBANG for the serious head injuries sustained by my son last February 18, 2020 while they were playing basketball at Brgy. 1, Malaybalay City, Bukidnon. 2. That before the complaint for Frustrated Murder was resolved unfortunately my son Jenzel del Rosario died last February 20, 2020 at Bethel Baptist Hospital.
Premises considered it is most respectfully prayed of to the
Honorable City Prosecutor that the complaint for Frustrated Murder be formally withdrawn and a complaint for Murder will be filed immediately against the same respondent ARIS GARCIA and TROY CABANGBANG.
Respectfully submitted this 21st day of February, 2020 at
Malaybalay City, Bukidnon. LIGHT ASSOCIATES LAW OFFICE Counsel for the Plaintiff. Barangay 1, Heights, Malaybalay City, Philippines
By: Kenneth Jade Celestial ROLL OF ATTORNEY’S NO. XXXXX-XX-XX-XX MCLE COMP. NO. V-XXXXXXX TIN: XXX-XXX-XXX PTR. NO. XXXXXXX-X-XX-XX-XX IBP NO. XXXXXX-XX-XX-XX MALAYBALAY CITY