SUBMITTED: KRISHA FAYE F.

AMBOL

(1.MOTION TO POSTPONE)

Republic of the Philippines

REGIONAL TRIAL COURT
11th Judicial Region
Branch 12
Davao City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE No.

Complainant, R-DVO-17-02935-CR &
R-DVO-17-02936-CR
-versus-

RRR T. WWW, FOR: VIOL OF RA 9165

Accused.

EX-PARTE MOTION TO POSTPONE THE MAY 17,

2021 HEARING

COMES NOW, Accused RRR T. WWW by Counsel unto this

Honorable Court, respectfully aver:

1. Accused through Counsel received an Order from this Honorable

Court setting the PRETRIAL on May 17, 2021;

2. However, Counsel cannot attend said hearing due to the fact that he
will avail professional rest from May 16 to 20, 2021 and will leave for
Lanao del Norte;

3. Counsel begs for the kind indulgence of this Honorable Court to reset
the scheduled hearing in the aforementioned case to another date
and manifests that the Accused and counsel has no intention to delay
the speedy disposition of the instant case and that this is done in
good faith;
 PRAYER

WHEREFORE, premises considered, it is respectfully prayed of this

Honorable Court to RESET the May 17, 2021 hearing of the instant case to
another date.

Other relief, just, and equitable are likewise prayed for.

May 16, 2021 Davao City, Philippines.

Assisted by:

AAA BBB CCCLAW OFFICE

Door #4 Doverlanes Bldg. A.
Bonifacio cor P. Gomez Sts., Amiya, EEEE Davao

ATTY AAA BBB CCC

Counsel for Accused
PTR No. 1731725 3 Jan 2021 DC
IBP No. 062578 4 Jan 2021 DC
IBP Roll No. 43867
MCLE Compliance No. VI-0012477 14 April 2023
Telephone/Fax No. (082) 225-5891

COPY FURNISHED / NOTICE:

CLERK OF COURT CITY PROSECUTOR
Branch 12-RTC City Prosecution Office
Davao City Davao City

Please set the foregoing motion for the favourable

consideration of this Honorable Office upon receipt hereof sans appearance
and without further arguments.

ATTY AAA BBB CCC

(2.MOTION FOR EXTENSION OF TIME)

Republic of the Philippines

REGIONAL TRIAL COURT
11th Judicial Region
Branch 12
Davao City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE No.

Complainant, R-DVO-17-02935-CR &
R-DVO-17-02936-CR
-versus-

RRR T. WWW, FOR: VIOL OF RA 9165

Accused.

Motion for Extension to Submit Judicial

Affidavit

COMES NOW, Accused RRR T. WWW through undersigned counsel unto this
Honorable Office, respectfully aver:

1. Last February 21, 2021, Accused received subpoena dated February

20, 2021 from this court directing Accused to file a Judicial Affidavit
10 days from receipt of the said document;

2. Accusedhave until March 3, 2021 to file said Judicial Affidavit needs

more time to exhaustively study and prepare the Judicial Affidavit to
be filed;

3. In view thereof, Accused would like to humbly ask for an extension of

ten (10) days within which to file his Judicial Affidavit;

4. This Motion is done in good faith and not intended to delay the
proceedings and/or disposition of the case.
 PRAYER

WHEREFORE, premises considered, it is respectfully prayed of this Honorable

Court to GRANT Accused an extension of ten (10) days or until March 13, 2021 within
which to file his Judicial Affidavit.

Other reliefs, just and equitable are likewise prayed for.

February 23, 2021, EEEE, Philippines.

Assisted by:

AAA BBB CCCLAW OFFICE

Door #4 Doverlanes Bldg. A.
Bonifacio cor P. Gomez Sts., Amiya, EEEE Davao

AAA BBB CCC

Counsel for Accused
PTR No. 1731725 3 Jan 2021 DC
IBP No. 062578 4 Jan 2021 DC
IBP Roll No. 43867
MCLE Compliance No. VI-0012477 14 April 2023
Telephone/Fax No. (082) 225-5891

COPY FURNISHED / NOTICE:

CLERK OF COURT CITY PROSECUTOR
Branch 12-RTC City Prosecution Office
Davao City Davao City

Please set the foregoing motion for the favorable consideration of the Honorable
Court on February 27, 2021at 8:30 a.m.
ATTY. AAA BBB CCC

(3.MOTION FOR INHIBITION)

Republic of the Philippines

REGIONAL TRIAL COURT
 11th Judicial Region
Branch 12
Davao City

WQR T. UIO, CIVIL CASE No.

Plaintiff, R-DVO-21-02935-CV

-versus-

RRR T. WWW, FOR: Damages

Defendant.

Motion for Inhibition

COMES NOW, Defendant RRR T. WWW through undersigned counsel unto this
Honorable Office, respectfully aver:

1. Last April 21, 2021, Defendant by counsel received information that

Honorable Judge YYY T. LLL’s daughter Ms. YYY U. LLLL got
married to plaintiff WQR T. UIO;

2. Under our rules, such relationship constitutes a ground for the

judge to inhibit in a case;

3. In view thereof, Defendant would like to humbly ask for Judge

YYY T. LLL to inhibit from this case;

4. This Motion is done in good faith and not intended to delay the
proceedings and/or disposition of the case.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of this Honorable

Court to GRANT Defendant an MOTION FOR INHIBITIONt.

Other reliefs, just and equitable are likewise prayed for.

 May 23, 2021, EEEE, Philippines.

Assisted by:

AAA BBB CCCLAW OFFICE

Door #4 Doverlanes Bldg. A.
Bonifacio cor P. Gomez Sts., Amiya, EEEE Davao

AAA BBB CCC

Counsel for Defendant
PTR No. 1731725 3 Jan 2021 DC
IBP No. 062578 4 Jan 2021 DC
IBP Roll No. 43867
MCLE Compliance No. VI-0012477 14 April 2023
Telephone/Fax No. (082) 225-5891

COPY FURNISHED / NOTICE:

CLERK OF COURT ATTY. OOO L. PPP
Branch 12-RTC Baguio Dist.
Davao City Davao City

Please set the foregoing motion for the favorable consideration of the Honorable
Court on May 27, 2021at 8:30 a.m.
ATTY. AAA BBB CCC

(4. MOTION FOR RECONSIDERATION)

Republic of the Philippines

REGIONAL TRIAL COURT
11th Judicial Region
Branch 12
Davao City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE No.

Complainant, R-DVO-17-02935-CR &
R-DVO-17-02936-CR
-versus-
RRR T. WWW, FOR: VIOL OF RA 9165
Accused.

Motion for Reconsideration

COMES NOW, Accused RRR T. WWW through undersigned counsel unto this
Honorable Office, respectfully aver:

1. Last February 21, 2021, Accused received the order from this
Honorable Court admitting the prosecution evidence exhibit J-
Judicial Affidavit of RR T. HA despite our opposition thereto;

2. In view thereof, Accused would like to reconsider such admittance

since the evidence was never testified to by the witness and infact
the witness never appeared in court to attest to the creation of
such affidavit;

3. This Motion is done in good faith and not intended to delay the
proceedings and/or disposition of the case.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of this Honorable

Court to GRANT Accused Motion for Reconsideration.

Other reliefs, just and equitable are likewise prayed for.

February 23, 2021, EEEE, Philippines.

Assisted by:

AAA BBB CCCLAW OFFICE

Door #4 Doverlanes Bldg. A.
Bonifacio cor P. Gomez Sts., Amiya, EEEE Davao

AAA BBB CCC

 Counsel for Accused
PTR No. 1731725 3 Jan 2021 DC
IBP No. 062578 4 Jan 2021 DC
IBP Roll No. 43867
MCLE Compliance No. VI-0012477 14 April 2023
Telephone/Fax No. (082) 225-5891

COPY FURNISHED / NOTICE:

CLERK OF COURT CITY PROSECUTOR
Branch 12-RTC City Prosecution Office
Davao City Davao City

Please set the foregoing motion for the favorable consideration of the Honorable
Court on February 27, 2021at 8:30 a.m.
ATTY. AAA BBB CCC

(5.MOTION TO ADMIT JUDICIAL AFFIDAVIT)

Republic of the Philippines

REGIONAL TRIAL COURT
11th Judicial Region
Branch 12
Davao City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE No.

Complainant, R-DVO-17-02935-CR &
R-DVO-17-02936-CR
-versus-

RRR T. WWW, FOR: VIOL OF RA 9165

Accused.

Motion to Admit Judicial Affidavit

COMES NOW, Accused RRR T. WWW through undersigned counsel unto this
Honorable Office, respectfully aver:
 1. Last March 21, 2021, Accused received the order from this
Honorable Court granting our motion to allow witness TTT Y. UUU
to testify in court;

2. In view thereof, Accused would like to endorse the witness TTT Y.

UUU, Judicial Affidavit in compliance with the rules;

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of this Honorable

Court to ADMIT The Judicial Affidavit of TTT Y. UUU.

Other reliefs, just and equitable are likewise prayed for.

March 23, 2021, EEEE, Philippines.

Assisted by:

AAA BBB CCCLAW OFFICE

Door #4 Doverlanes Bldg. A.
Bonifacio cor P. Gomez Sts., Amiya, EEEE Davao

AAA BBB CCC

Counsel for Accused
PTR No. 1731725 3 Jan 2021 DC
IBP No. 062578 4 Jan 2021 DC
IBP Roll No. 43867
MCLE Compliance No. VI-0012477 14 April 2023
Telephone/Fax No. (082) 225-5891

COPY FURNISHED / NOTICE:

CLERK OF COURT CITY PROSECUTOR
Branch 12-RTC City Prosecution Office
Davao City Davao City

Please set the foregoing motion for the favorable consideration of the Honorable
Court on March 27, 2021 at 8:30 a.m.
ATTY. AAA BBB CCC
(6. MOTION TO ADMIT DEFENSE EVIDENCE)

Republic of the Philippines

REGIONAL TRIAL COURT
11th Judicial Region
Branch 12
Davao City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE No.

Complainant, R-DVO-17-02935-CR &
R-DVO-17-02936-CR
-versus-

RRR T. WWW, FOR: VIOL OF RA 9165

Accused.

Motion to Admit Defense Evidence

COMES NOW, Accused RRR T. WWW through undersigned counsel unto this
Honorable Office, respectfully aver:

1. Last March 21, 2021, Accused received the copy of CCTV footage
from Bago Gallera on March 30, 2021, which is an integral part of
Accused defense (attached and marked herein as EXHIBIT W).

2. In view thereof, Accused would like to ask the court to admit the
CCTV Footage as part of Accused defense evidence to be marked
as Exhibit W.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of this Honorable

Court to ADMIT the CCTV FOOTAGE from Bago Gallera on March 30, 2021

Other reliefs, just and equitable are likewise prayed for.

March 23, 2021, EEEE, Philippines.

 Assisted by:

AAA BBB CCCLAW OFFICE

Door #4 Doverlanes Bldg. A.
Bonifacio cor P. Gomez Sts., Amiya, EEEE Davao

AAA BBB CCC

Counsel for Accused
PTR No. 1731725 3 Jan 2021 DC
IBP No. 062578 4 Jan 2021 DC
IBP Roll No. 43867
MCLE Compliance No. VI-0012477 14 April 2023
Telephone/Fax No. (082) 225-5891

COPY FURNISHED / NOTICE:

CLERK OF COURT CITY PROSECUTOR
Branch 12-RTC City Prosecution Office
Davao City Davao City

Please set the foregoing motion for the favorable consideration of the Honorable
Court on March 27, 2021 at 8:30 a.m.
ATTY. AAA BBB CCC

(7. MOTION FOR LEAVE OF COURT TO FILE DEMURRER)

Republic of the Philippines

REGIONAL TRIAL COURT
11th Judicial Region
Branch 12
Davao City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE No.

Complainant, R-DVO-17-02935-CR &
R-DVO-17-02936-CR
-versus-

RRR T. WWW, FOR: VIOL OF RA 9165

Accused.
 MOTION FOR LEAVE
TO FILE DEMURRER TO EVIDENCE
COMES NOW, Accused RRR T. WWW through undersigned counsel unto this
Honorable Office, respectfully aver:

1. Last February 16, 2021, the Prosecution rested its case and within
five (5) days therefrom, Accused WWW asks for leave to file his
demurrer to evidence;

2. Accused WWW posits that the Prosecution failed to prove his guilt
with proof beyond reasonable doubt on the ground that: THE
PROSECUTION FAILED TO POSITIVELY IDENTIFY ACCUSED
PABILAN AS THE VERY PERSON WHO COMMITTED THE
CRIME OF ROBBERY.

PRAYER
WHEREFORE, premises considered, it is respectfully prayed of this
Honorable Court to GRANT Accused WWW’s Motion for leave to File
Demurrer to Evidence and GRANT ten (10) days from receipt of Order to
file such pleading.

Other relief, just and equitable are likewise prayed for.

February 18, 2021 Davao City, Philippines.

Assisted by:

AAA BBB CCCLAW OFFICE

Door #4 Doverlanes Bldg. A.
Bonifacio cor P. Gomez Sts., Amiya, EEEE Davao
 AAA BBB CCC
Counsel for Accused
PTR No. 1731725 3 Jan 2021 DC
IBP No. 062578 4 Jan 2021 DC
IBP Roll No. 43867
MCLE Compliance No. VI-0012477 14 April 2023
Telephone/Fax No. (082) 225-5891

COPY FURNISHED / NOTICE:

CLERK OF COURT CITY PROSECUTOR
Branch 12-RTC City Prosecution Office
Davao City Davao City

Please set the foregoing motion for the favorable consideration of the Honorable
Court on March 27, 2021 at 8:30 a.m.
ATTY. AAA BBB CCC

(8. EXPARTE-MOTION FOR LEAVE OF COURT TO ALLOW WAKE

VISITATION)

Republic of the Philippines

REGIONAL TRIAL COURT
11th Judicial Region
Branch 12
Davao City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE No.

Complainant, R-DVO-17-02935-CR &
R-DVO-17-02936-CR
-versus-

RRR T. WWW, FOR: VIOL OF RA 9165

Accused.

URGENT EX-PARTE MOTION TO ALLOW

 ACCUSED TO VISIT HIS MOTHER’S WAKE, WHO
DIED LAST MARCH 28 2021,
ON APRIL 1, 2019 FROM 8AM-12 P.M . WITH
ESCORT FROM THE BJMP
ACCUSEDby Counsel, respectfully aver:

1. Accused’s mother, the late Mrs.RRR YYYY died last MARCH 28

2021 in Davao City and her wake is being held in St. Peter
Funeral Home, Panacan, Davao City and she is supposed to be
interred on April 2, 2021 in Davao Memorial Cemetery at Matina,
Davao City. Arnulfo A. Basan herein attaches the following
documents:

a. ACCUSED’S birth certificate showing his parent’s name;

b. Mrs.RRR YYYY death certificate who died last MARCH

28 2021;

2. Accused pleas that he be allowed to visit his mother’s WAKE on

APRIL 1, 2019 from 8:00 a.m. to 12:00 p.m. in St. Peter Funeral
Home, Panacan, Davao City. Accused, before his arrest, served his
mother as her caretaker for several years, and he is now
overcome by grief and seeks to show his last respect to his
parent;

Accused prays that he be duly escorted for this purpose and that
he will shoulder any and all costs for his visit;

PRAYER
WHEREFORE premises considered, it is respectfully prayed of this
Honorable Court to GRANT Accusedplea to visit his mother wake, on April
1, 2021 at St. Peter Funeral Home, Panacan, Davao City.

Other relief, just and equitable are likewise prayed for.

 March 29, 2021 Davao City, Philippines.

Assisted by:

AAA BBB CCCLAW OFFICE

Door #4 Doverlanes Bldg. A.
Bonifacio cor P. Gomez Sts., Amiya, EEEE Davao

AAA BBB CCC

Counsel for Accused
PTR No. 1731725 3 Jan 2021 DC
IBP No. 062578 4 Jan 2021 DC
IBP Roll No. 43867
MCLE Compliance No. VI-0012477 14 April 2023
Telephone/Fax No. (082) 225-5891

COPY FURNISHED / NOTICE:

CLERK OF COURT CITY PROSECUTOR
Branch 12-RTC City Prosecution Office
Davao City Davao City

Please set the foregoing motion for the favorable consideration of the Honorable
Court sans appearances.
ATTY. AAA BBB CCC

(9. MOTION TO HEAR ACCUSED PLEA BARGAIN)

Republic of the Philippines

REGIONAL TRIAL COURT
11th Judicial Region
Branch 12
Davao City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE No.

Complainant, R-DVO-17-02935-CR &
R-DVO-17-02936-CR
 -versus-

RRR T. WWW, FOR: VIOL OF RA 9165

Accused.

MOTION TO HEAR ACCUSED’S PROPOSAL

TO PLEA BARGAIN
Comes now, Accused RRR T. WWW through counsel, unto this
Honorable Court, respectfully aver:

1. Accused is charged of the following crime with the corresponding

volume of alleged corpus delicti:

a. Violation of Section 5 – alleged sale of Shabu for 0. 2303

grams.

2. Accused had been detained for 1 year, 11 months and 24 days

already;

3. Accused, heard of the latest development of cases involving

violations of R.A. No. 9165 particularly involving PLEA
BARGAINING, and now proposes to the Prosecution to be able to
plea bargain on terms, pursuant to “A.M. No. 18-03-16-SC -
Adoption of the Plea Bargaining Framework in Drugs Cases.”
– (See proposal herein attached and marked as Annex A);

4. Accused has no prior derogatory record and is a first-time

offender.

PRAYER
WHEREFORE premises considered it is respectfully prayed of this
Honorable Court to set this case for hearing for Accused proposal to plea
bargain.
Other relief, just and equitable are likewise prayed for.

April 10, 2021 Davao City, Philippines.

Assisted by:

AAA BBB CCCLAW OFFICE

Door #4 Doverlanes Bldg. A.
Bonifacio cor P. Gomez Sts., Amiya, EEEE Davao

AAA BBB CCC

Counsel for Accused
PTR No. 1731725 3 Jan 2021 DC
IBP No. 062578 4 Jan 2021 DC
IBP Roll No. 43867
MCLE Compliance No. VI-0012477 14 April 2023
Telephone/Fax No. (082) 225-5891

COPY FURNISHED / NOTICE:

CLERK OF COURT CITY PROSECUTOR
Branch 12-RTC City Prosecution Office
Davao City Davao City

Please set the foregoing motion for the favorable consideration of the Honorable
Court on April 13, 2021 at 8:30 am.
ATTY. AAA BBB CCC

(10. EXPARTE-MOTION TO WITHDRAW AS COUNSEL)

Republic of the Philippines

REGIONAL TRIAL COURT
11th Judicial Region
Branch 12
Davao City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE No.

 Complainant, R-DVO-17-02935-CR &
R-DVO-17-02936-CR
-versus-

RRR T. WWW, FOR: VIOL OF RA 9165

Accused.

EX-PARTE MOTION TO WITHDRAW AS

COUNSEL WITH CONSENT
COMES NOW, Counsel for the Accused RRR T. WWW, into this
Honorable Court, most respectfully aver:

1. Accused intends to secure the assistance of new Counsel

whose name will later be divulged;

2. Upon approval of this Honorable Court, all pleadings, notices

and papers in connection with this case be addressed to their
new Counsel;

3. Furthermore, Accused is relieved from all financial

responsibilities from Undersigned Counsel and the latter has no
accountability, financial or tasks, to his client;

4. For this reason, Undersigned Counsel humbly asks that he be

relieved of his duties and responsibilities;

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of this

Honorable Court to allow the Undersigned Counsel to withdraw as Counsel
for the Accused RRR T. WWW,;

Other relief, just and equitable are likewise prayed for.

 April 10, 2021. Davao City, Philippines.

With my Conformity:

RRR T. WWW

Accused
Assisted by:

AAA BBB CCCLAW OFFICE

Door #4 Doverlanes Bldg. A.
Bonifacio cor P. Gomez Sts., Amiya, EEEE Davao

AAA BBB CCC

Counsel for Accused
PTR No. 1731725 3 Jan 2021 DC
IBP No. 062578 4 Jan 2021 DC
IBP Roll No. 43867
MCLE Compliance No. VI-0012477 14 April 2023
Telephone/Fax No. (082) 225-5891

COPY FURNISHED / NOTICE:

CLERK OF COURT CITY PROSECUTOR
Branch 12-RTC City Prosecution Office
Davao City Davao City

Please set the foregoing motion for the favorable consideration of the Honorable
Court on April 13, 2021 at 8:30 am.
ATTY. AAA BBB CCC