REPUBLIC OF THE PHILIPPINES

FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
VIGAN CITY, ILOCOS SUR
BRANCH 20
IN RE: OMNIBUS APPLICATION
FOR
RELEASE;
BAIL;
RECOGNIZANCE
Case No.
_____________
JANSEN USANA, RYAN OLIVER,
MINELIO OLIVER, JR. AND
FRODELIO UMANI,
Applicants,
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URGENT OMNIBUS APPLICATION
Applicants-Movants JANSEN USANA, RYAN OLIVER,
MINELIO OLIVER, JR. AND FRODELIO UMANI, by counsel,
respectfully state:
1.
Herein applicants of the instant Omnibus Motion,
except for Frodelio Umani, are the respondents of the Search
Warrant Nos. 19-16, 20-16, 21-16 and 22-16, series of 2016
issued by this Honorable Court for alleged violations of R.A.
Nos. 9165 and 10591 which were simultaneously
implemented on 29 March 2016 at around 5:00 o’clock a.m.,
in Brgy. Patong, Magsingal, Ilocos Sur by the elements of PNPCIDG, Ilocos Sur.
2.
The implementation of the said search warrants on
said respondents purportedly resulted to the discovery and
seizure of firearms and ammunitions by the said law
enforcers and eventually to the arrest and detention of herein
applicants, including Umani by his mere presence in one of
the subject places of implementation, since 5:30 o’clock a.m.
of 29 March 2016 and until this date initially at the detention
cell of PNP-CIDG Ilocos Sur at Camp Pres. Elpidio Quirino,
Bulag, Bantay, Ilocos Sur but later transferred to the PNP
Police Station of Magsingal, Ilocos Sur.

1

applicants are willing to be released on recognizance to the Municipal Mayor of Magsingal. Magsingal. From their arrest and detention on the early morning of 29 March 2016 until this date.3. Patong. Consequently. Branch 24. 6. both of Ilocos Sur or even assuming that they filed the same. Ilocos Sur or Brgy.no release of persons under detention by legal process shall be made except upon order of the court or when he/they is/are admitted to bail. the PNP-CIDG Ilocos Sur failed to deliver the herein applicants to the proper judicial authorities for their criminal prosecution to said crimes or even to the OPP-IS for inquest or preliminary investigation which could make them liable for violation of Article 125 of the Revised Penal Code. Patong and Maas-asin of Magsingal. Ilocos Sur. Considering the foregoing and considering further the rule on Section 3 Rule 114 of the Revised Rules on Criminal Procedure that . Applicants are filing this motion before this Honorable Court being the issuing court of said Search Warrants and considering the absence of the Presiding Judge of the Regional Trial Court of Cabugao. 8. Applicants undertake to comply with any order of the Honorable Court and will appear before the same or any court or government agency if ordered to do so. In the alternative. 2 . however. 7. for a period of more than two (2) days or forty eight (48) hours. failed to file their criminal complaint against the applicants before the Office of the Provincial Prosecutor of Ilocos Sur (OPP-IS) primarily due to the convention of DOJ Prosecutors since 30 to 31 of March 2016 then held at Candon City and still ongoing to this date at Caoayan. still no inquest or preliminary investigation proceedings have been conducted for the said period. 4. the PNP-CIDG Ilocos Sur. Ilocos Sur and would appear before the Honorable Court if required or that they be allowed to post bail for their temporary liberty on such reasonable amount of bailbond as may be warranted by their financial capability considering that they are members of the indigent families of Brgy. 5. applicants pray for their immediate release on detention pending the filing of the criminal complaint against them by the PNP-CIDG Ilocos Sur before the OPP-IS. Ilocos Sur. Chairman of Brgy.

Ilocos Sur to release the applicants herein immediately from detention and/or in the alternative. attached herein and marked as Annexes A to G. No. 1020268– 01/20/16–Ilocos Sur PTR No. Elpidio Quirino Bulag. their respective Certificates of Indigency issued by the Brgy. Ilocos Sur Greetings: 3 . Certification issued by the Regional Trial Court of Cabugao. 49490 IBP No. Ilocos Sur.9. Branch 24 and Certificate of Detention of PNP Magsingal. applicants are submitting the Photograph of the Notice issued by the OPP-IS. 2nd Floor. Ilocos Sur PNP MAGSINGAL. premises considered. PRAYER WHEREFORE. ILOCOS SUR Magsingal. 2700 Ilocos Sur Roll of Attorneys No. Other reliefs. Chairman of said barangays. Cert. In support of this motion. Liberation Bvd. respectively. 2766999 – 01/20/16–Ilocos Sur MCLE Comp. it is respectfully prayed before this Honorable Court that an order be issued to the PNP-CIDG-Ilocos Sur and/or PNP Magsingal. Bantay. TOLENTINO Counsel for the Applicants Unit V. just and equitable under the premises. IV-00005723–09/05/ 2012 REQUEST/NOTICE/COPY FURNISHED/EXPLANATION PNP-CIDG ILOCOS SUR Camp Pres. Isidoro Building Quezon Avenue cor. Ilocos Sur OFFICE OF THE PROVINCIAL PROSECUTOR Vigan City. MELVER G. are likewise prayed for. Vigan City. Ilocos Sur. Magsignal. that they be allowed to be released on recognizance or on bail for their temporary liberty. 31 March 2016.

The undersigned further caused the service and filing of this motion to the abovesaid parties via personal service to the PNP Magsingal. personnel and urgency hereof. Sur and via registered mail with return card to the PNP-CIDG Ilocos Sur and Office of the Provincial Prosecutor of Ilocos Sur due to lack of material time. JR. __________________ RYAN T. I. OLIVER ____________________ FRODELIO UMANI 4 . OLIVER.Please be informed that the undersigned will be filing the instant Urgent Omnibus Motion before the Honorable Court for its immediate consideration and resolution upon receipt hereof due to the extreme urgency of the matter. TOLENTINO With Our Express Conformity: ________________ JANSEN USANA ________________________ MINELIO T. MELVER G.