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raffy matias application for probation

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13 views3 pages

raffy matias application for probation

Uploaded by

nicholo
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


Second Judicial Region
BRANCH 03
Carig, Tuguegarao City

PEOPLE OF THE PHILIPPINES, CRIM. CASE NO.24203

-versus-

RAFFY MATIAS y TACAMA


Accused.
x----------------------------------------x

APPLICATION FOR PROBATION

Accused-movant, by counsel, unto this Honorable Court and in every


humblest way possible, states that:

ACCUSED, through the undersigned counsel and unto this Honorable Court,
most respectfully applies for probation under the provisions of Presidential Decree
No. 968 as amended and states that:
On March 26, 2024 this Honorable Court rendered judgment against
accused wherein accused was convicted of the crime for violation of “Section 31
of R.A. 10591” and was sentenced to suffer the indeterminate penalty of 4
months of aresto mayor as minimum to 3 years of prision coreccional as
maximum, and to pay a FINE of P10,000.00. On motion, thru counsel accused was
allowed to avail of post judgment remedies pending finality of judgment;
The crime for which the accused was convicted is not an offense against
national security or public order;
Accused has not been previously convicted by final judgment of any offense
punishable by imprisonment of more than six (6) years;
Accused has not been once placed on probation under the provisions
of Presidential Decree No. 968, otherwise known as the Probation Law of 1976, as
amended;
Accused has all the qualifications and none of the disqualifications to avail
of the benefits of the Probation Law.

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of this
Honorable Court that the Application for Probation be referred to the Parole and
Probation Officer of Tuguegarao City for the requisite post-sentence investigation
and thereafter, the application for probation be approved.

Other just and equitable reliefs are likewise prayed for.

Respectfully submitted

April 5, 2024 Tuguegarao City, Cagayan

CHO-LAW OFFICE
Counsel for the Accused
Stall No. 3, Mama Remedios Food Hub
67 Balzain East, Tuguegarao City, Cagayan
Back of ChinaBank, Balzain Branch
[email protected]
by:

ATTY. NICHOLO RUDOLF A. SUPNET


Roll No. 54755
PTR No. TUG3194871/01-13-23/Tuguegarao City, Cagayan
IBP No. Lifetime No. 011542/Tuguegarao City, Cagayan
MCLE Complied (Certificate not yet issued)
0916-946-3428
[email protected]

NOTICE

To: The Branch Clerk of Court


To: Assigned Prosecutor on Case

SIR/MADAME:

Greetings!

Respectfully submitting the foregoing motion to the consideration of the


Honorable Court.

Thank you!

ATTY. NICHOLO RUDOLF A. SUPNET


Copy furnished:

Copy furnished:
PROS. JOEL T. DALIUAG
Office of the Provincial Prosecutor
National Prosecution Service
Regional Government Center
Tuguegarao City, Cagayan
[email protected]
[email protected]
EXPLANATION FOR SERVICE BY ELECTRONIC MAIL
In compliance with Section 11 of Rule 13 of the 1997 Rules of Civil Procedure, undersigned
counsel respectfully manifests that the foregoing MOTION is being served by ELECTRONIC mail on
the e-mail addresses of counsels because of time and distance constraints, as well as the
prevailing public health emergency, which render personal service impracticable.

ATTY. NICHOLO RUDOLF A. SUPNET

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