Republic of the Philippines

Ninth Judicial Region

REGIONAL TRIAL COURT
Zamboanga City, Branch 3
PEOPLE OF THE
PHILIPPINES,
Plaintiff,
-versus-

Crim. Case. No. 12-345 and 12-346

FOR: Violations of Sec. 5 and 11 of
R.A. 9165

JOSE BEBE DELA CRUZ,

Accused.
x-----------------------------------------x
MOTION FOR LEAVE OF COURT
TO FILE DEMURRER TO EVIDENCE
COMES NOW, the accused, JOSE BEBE DELA CRUZ, through
undersigned counsel and unto this Honorable Court, most respectfully avers
that:
1. On February 18, 2015, the prosecution have finished presenting and
offering their evidences to this Honorable Court and have rested their
case;
2. Objections and admissions to the said evidences have also been made
by the accused, through counsel, in the same day;
3. The accused-defendant finds that the evidence presented by the
prosecution are insufficient and does not prove the commission of any
of the alleged crimes charged against him;
4. Thus, through counsel, the accused-defendant, asks this Honorable
Court for leave of court to file for a demurrer to evidence pursuant to
Rule 33 of the Rules of Court.
PRAYER
WHEREFORE, the accused, through counsel, requests that the Court
issue an order for the leave of court to allow the filling of demurrer to
evidence.
Such other reliefs that are just and equitable under the premises are
likewise prayed for.
Zamboanga City

February 18, 2015

Respectfully submitted,
ATTY. BENSAUD O. DEGUSMAN
Counsel for the Accused-Defendant
Commission Serial Number: 123221
Notary Public for Zamboanga City
Until December 31, 2015
Nunez St. Zamboanga City
Roll No: 99821
IBP Lifetime Roll No: 22314, 1/2/12; Zamboanga City
Professional Tax Receipt No: 23142; 12/2/15; Zamboanga City
MCLE Compliance Certificate No.: 214142; 12/2/15.
NOTICE OF HEARING
The Clerk of Court
Branch 3, Regional Trial Court
Ninth Judicial Region
Zamboanga City
Kindly submit the foregoing Motion for Leave of Court to File
Demurrer of Evidence for consideration of the Court immediately upon
receipt hereof.
ATTY. BENSAUD O. DEGUSMAN
Counsel for Accused-Defendant
Copy Furnished:
ATTY. JORDACHE RAMOS
Counsel for the Prosecution
Prosecutor's Office
Hall of Justice, Zamboanga City