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Motion To Change Address

1) Jose Santos was charged with violating Section 11 of the Comprehensive Dangerous Drugs Act of 2002 and entered into a plea bargain where he was sentenced to 6 months and 1 day imprisonment and a fine of 10,000 pesos, and was ordered to undergo drug dependency examination and 6 months of outpatient rehabilitation. 2) Santos' lawyer has now filed a motion requesting that the court allow Santos to transfer his probation supervision to Talisay City so he can enroll in counseling and drug rehabilitation at the Poblacion Talisay RHU. 3) The motion prays that the court issue an order granting the transfer of Santos' probation supervision to facilitate his rehabilitation in Talisay City.

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58 views2 pages

Motion To Change Address

1) Jose Santos was charged with violating Section 11 of the Comprehensive Dangerous Drugs Act of 2002 and entered into a plea bargain where he was sentenced to 6 months and 1 day imprisonment and a fine of 10,000 pesos, and was ordered to undergo drug dependency examination and 6 months of outpatient rehabilitation. 2) Santos' lawyer has now filed a motion requesting that the court allow Santos to transfer his probation supervision to Talisay City so he can enroll in counseling and drug rehabilitation at the Poblacion Talisay RHU. 3) The motion prays that the court issue an order granting the transfer of Santos' probation supervision to facilitate his rehabilitation in Talisay City.

Uploaded by

adrianne
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Republic of the Philippines

REGIONAL TRIAL COURT


7TH JUDICIAL REGION
Branch 53
City of Cebu

PEOPLE OF THE PHILIPPINES,


Plaintiff, Crim. Case No. DU-47706
For: Viol. of Sec. 11, ART. II OF RA 9165
-versus-

JOSE SANTOS,
Accused,
X - - - - - - - - - - - - - - - - - - - - - - - - - -/

MOTION TO CHANGE REPORTORIAL DUTIES


COMES NOW, the undersigned counsel for the accused and to this
Honorable Court, most respectfully moves and aver THAT:

1. Herein accused was charged for violation of Section 11 Article II of


Republic Act No. 9165 before the Regional Trial Court (RTC) Branch 56 of
Cebu City and he subsequently entered into plea bargaining with the State
and he was then sentenced to suffer the penalty of Six (6) months and One
(1) day of imprisonment and to pay a fine of P10,000.00 and subsequently
applied for Probation;

2. Accused was also directed to submit himself for Drug Dependency


Examination (DDE) which he faithfully complied as such, this Honorable
Court issued an ORDER dated 14 January 2020, ordering herein accused to
undergo outpatient rehabilitation for at least six (6) months under the care
and custody of Cebu City Substance Abuse Prevention Office (MCSAPO)
in close coordination with the Chairman of the Barangay Anti-Drug Abuse
Council (BADAC) of Brgy. Lahug, Cebu City;

PRAYER

WHEREFORE, premises considered, Accused, through the undersigned


counsel begs the kindest indulgence of this Honorable Court and pray that an
ORDER be issued transferring the supervision of his Probation in Talisay City
allowing herein accused to enroll himself for counselling and drug
rehabilitation at the Poblacion Talisay RHU as we pray for other reliefs just and
equitable under the premises.

Respectfully Submitted. City of Cebu, Cebu, Philippines. 16 June 2023.

Department of Justice
HALAS LAW FIRM
Hall of Justice

By:

JENETTE DELA CRUZ


Roll of Attorney’s No. 67736
IBP Lifetime No. 02234
MCLE no. VII-0026843
Valid until April 14, 2025

THE CLERK OF COURT


RTC – BRANCH 56
Cebu City

Madam:

Greetings! Please submit the foregoing Motion for the consideration of the Honorable Court at the soonest possible
date and time as the calendar of the court would permit. Thank you!

JENETTE DELA CRUZ

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