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Urgent Motion For Early Resolution-Maam Bernabe

Jazelle Faith Bianca Bernabe filed an urgent motion for early resolution of her criminal case against Jean Clarizze Lacerna for two counts of violating the Bouncing Checks Law. The complainant argues that the respondent's failure to submit a counter-affidavit waives her right to a defense and expresses concern that the respondent may leave the country, potentially frustrating justice. Bernabe requests a prompt resolution to prevent undue delay in the case.

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Kenneth Martin E. Dela Cruz
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4 views4 pages

Urgent Motion For Early Resolution-Maam Bernabe

Jazelle Faith Bianca Bernabe filed an urgent motion for early resolution of her criminal case against Jean Clarizze Lacerna for two counts of violating the Bouncing Checks Law. The complainant argues that the respondent's failure to submit a counter-affidavit waives her right to a defense and expresses concern that the respondent may leave the country, potentially frustrating justice. Bernabe requests a prompt resolution to prevent undue delay in the case.

Uploaded by

Kenneth Martin E. Dela Cruz
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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Republic of the Philippines

Department of Justice
NATIONAL PROSECUTION SERVICE
OFFICE OF THE PROVINCIAL PROSECUTOR
PROVINCE OF BULACAN

JAZELLE FAITH BIANCA BERNABE,


Complainant,
NPS DOCKET No. III-04-INV-
25A-00345 to 00346
-versus- For: Two (2) Counts of
Violation of Batas Pambansa
Blg. 22.
JEAN CLARIZZE LACERNA,
Respondent.

URGENT MOTION
FOR EARLY RESOLUTION
Complainant, appearing pro se, to the Honorable Prosecutor,
respectfully states THAT:

1. The above-entitled case is a criminal action for violation of two


counts under Batas Pambansa Blg. 22, otherwise known as the
Bouncing Checks Law;

2. That the criminal action was filed on January 27, 2025. Considering
that the respondent did not file her responsive counter-affidavit
within the prescribed period, such failure constitutes a waiver of her
right to present a defense, pursuant to Section 3(b), Rule 112 of the
Rules of Criminal Procedure, which provides that non-submission
of a counter-affidavit within the given period authorizes the
investigating officer to resolve the complaint based solely on the
evidence presented by the complainant;

3. The complainant does not seek special treatment but respectfully


urges an early resolution of this case, as it has come to her attention
that the respondent is planning to leave the country. Should the
respondent be allowed to travel without restriction, there is a risk of
frustrating the due administration of justice. Attached hereto is a
notarized affidavit from my colleague, attesting to a conversation

Page 1 of 4
confirming the respondent’s intent to travel abroad, marked as
ANNEX “A-Series”;

4. In the interest of justice and to prevent undue delay, the complainant


respectfully moves for the immediate resolution of this case in
accordance with Section 12, Rule 112 of the Rules of Criminal
Procedure, which mandates a prompt disposition of complaints
based on the evidence presented.

WHEREFORE, based on the foregoing premises, it is most respectfully


prayed that this Honorable Office render a resolution on this case at the
earliest possible time.

Other just and equitable reliefs are likewise prayed for.

Respectfully submitted this 14th Day of March 2025, in Malolos City,


Province of Bulacan.

Page 2 of 4
NOTICE OF HEARING

Office of the Provincial Prosecutor

Greetings:

Please take notice that the undersigned will submit the foregoing
motion for the Honorable Office’s consideration immediately upon receipt
hereof without further oral arguments and without presence of
counsels/parties. Thank you.

EXPLANATION

Copies of the foregoing Motion have been duly filed and served via
registered mail, considering the geographical distance between the offices
concerned and the unavailability of dedicated messengerial personnel.

Copy furnished:

CHESTER D. NATIVIDAD
Prosecuting Attorney

JEAN CLARIZZE LACERNA


Kalsadang Bago, Kaingin, San Rafael, Bulacan

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VERIFICATION AND CERTIFICATION
OF NON-FORUM SHOPPING

I, JAZELLE FAITH BIANCA BERNABE, of legal age, Filipino,


and a resident of Luwasan, Catmon, Sta. Maria, Bulacan, after having
been duly sworn in accordance with law, hereby depose and state
THAT:

1. I am the Complainant in the above-captioned case and have caused


the preparation of this Urgent Motion for Early Resolution;

2. I have read and understood the contents thereof and affirm that the
statements contained therein are true and correct based on my
personal knowledge and authentic records;

3. I certify that I have not commenced any other action or proceeding


involving the same issues in any court, tribunal, or quasi-judicial
agency, and to the best of my knowledge, no such other action or
proceeding is pending before any court or tribunal;

4. If I should learn that a similar action or proceeding has been filed or is


pending, I undertake to promptly inform this Honorable Office within
five (5) days from knowledge thereof.

IN WITNESS WHEREOF, I have hereunto affixed my signature this


14th day of March 2025 in Malolos City, Bulacan.

JAZELLE FAITH BIANCA BERNABE


Affiant

SUBSCRIBED AND SWORN TO before me this 14th day of


March 2025, in Malolos City, Bulacan, affiant exhibiting to me her
valid government-issued ID No. ________, issued on ______ at
______.
Notary Public

Doc. No.: ____


Page No.: ____
Book No.: ____
Series of 2025.

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