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TABLE OF CONTENTS

1. Criminal information for Murder


2. Criminal information for Homicide
3. Criminal information for Libel
4. Criminal information for BP Blg 22
5. Motion to quash criminal complaint
6. Demurrer to Evidence
7. Petition for Bail
8. Motion to Reduce Bond/Bail
9. Motion to Suspend Proceedings
10. Ex Parte Motion to set the case for pre-trial conference
REPUBLIC OF THE PHILIPPINES
National Capital Judicial Region
REGIONAL TRIAL COURT
City of Manila
Branch 44

PEOPLE OF THE PHILIPPINES,


Plaintiff,

-versus- CRIMINAL CASE NO. 24242


For: Murder

EARL ESTACIO,
Defendant.
x-----------------------------------------------------x

INFORMATION

The undersigned Assistant City Prosecutor, upon sworn


complaint originally filed by the offended party, accuses EARL
ESTACIO of the crime of MURDER, committed as follows:

That on or about January 15, 2017 in the city of Balanga,


province of Bataan, Philippines, within the jurisdiction of this court,
the said accused, did then and there, with malice aforestated and
with deliberate intent to take the life of ANGELA SABAUPAN,
wilfully, unlawfully, feloniously, suddenly and treacherously attack
the latter with a knife, fist wounding him in the chest, and
afterwards, when enfeebled and unable to defend himself, again in
the stomach, both wounds being necessarily mortal, thereby
causing the direct and immediate death of said ANGELA
SABAUPAN.

Contrary to law.

Bataan, Philippines. April 2, 2017

(SGD) Earl Estacio


Assistant City Prosecutor

Witnesses: 1. Ricky Flores 12 Del Monte Quezon City


2. Beth Tamayo 222 Mayon Quezon City

Bail Recommended: P10,000


CERTIFICATION

I hereby certify that the preliminary investigation in this case


has been conducted; I have examined the complaint and his
witnesses and on the basis of their sworn statements and other
evidence submitted before me there is reasonable ground to
believe that the offense charged has been committed; the accused
was informed of the complaint and was given an opportunity to
submit controverting evidence and that the filing of this
information was with the authority of the City Prosecutor.

Earl Estacio

SUBSCRIBED AND SWORN to before me this 3rd day of MARCH


2017. Balanga, Bataan.

Randy David
Administering officer
Republic of the Philipines
National Capital Judicial Region
REGIONAL TRIAL COURT
Branch 22, Quezon City

PEOPLE OF THE PHILIPPINES,


Plaintiff,

-versus- Criminal Case: 12345


For: Libel

Dr. Alicia Santos and Fr. Rolly Dela Vega,


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

INFORMATION

The undersigned prosecutor accuses Dr. Alicia Santos and Fr.


Rolly Dela Vega of the crime of libel, committed as follows:

On or about 22 December 2015 in the City of Quezon, the


accused, being then the editors in newspapers titled Pilipinas
Balita, published in general circulation in the Philippines,
voluntarily, feloniously and with the intention of attacking the
honesty, virtue and reputation of ABA Educational System Inc. and
for the purpose of exposing her to public hatred and ridicule, wrote
in Issue No. 123 of said newspaper, an injurious and defamatory
article which is in words as follows:

Ang kapal naman ng mukha ng eskwelahang ito, itong si


ABA Educational System, para magpatuloy sa pagtanggap ng mga
estudyante at pagtanggap ng enrollees kahit na walang permit
galling sa CHED. Hindi dapat pinapahintulutan itong eskwelahang
ito na ipagpatuloy ang kanilang illegal na aktibidad sapagkat
sinisira lamang nila ang buhay ng mga batang ito at binibigyan nila
ng false hope ang kinabukasan nila.

The article in question had for its object to insinuate and made
it understood, and interpreted by the public who read it, that the
school referred to is no other that ABA Educational System Inc, and
in this manner transmitting maliciously to the public the impression
that the school has no permit to operate as an educational
institution, with the purpose of destroying their reputation before
the bar of public opinion.

Contrary to Law.
Quezon City, 22 February 2016.

(SGD) Laurence Taguinod


Assistant City Prosecutor

Witnesses: 1. Ricky Flores 12 Del Monte Quezon City


2. Beth Tamayo 222 Mayon Quezon City

Bail Recommended: P10,000

CERTIFICATION

I hereby certify that the preliminary investigation in this case


has been conducted; I have examined the complaint and his
witnesses and on the basis of their sworn statements and other
evidence submitted before me there is reasonable ground to
believe that the offense charged has been committed; the accused
was informed of the complaint and was given an opportunity to
submit controverting evidence and that the filing of this
information was with the authority of the City Prosecutor.

Laurence Taguinod

Subscribed and sworn to before me this 27 February 2016 in


Quezon City.

Ricardo Puno
Administering officer
REPUBLIC OF THE PHILIPPINES
National Capital Judicial Region
REGIONAL TRIAL COURT
City of Manila
Branch 44

PEOPLE OF THE PHILIPPINES,


Plaintiff,

-versus- CRIMINAL CASE NO. 24242


For: Homicide

EARL ESTACIO,
Defendant.
x-----------------------------------------------------x

INFORMATION

The undersigned Assistant City Prosecutor, upon sworn


complaint originally filed by the offended party, accuses EARL
ESTACIO of the crime of MURDER, committed as follows:

That on or about January 15, 2017 in the city of Balanga,


province of Bataan, Philippines, within the jurisdiction of this court,
the said accused, did then and there, with malice aforestated and
with deliberate intent to take the life of NICU DELA MERCED,
wilfully, unlawfully, feloniously, suddenly and treacherously attack
the latter with a knife, fist wounding him in the chest, and
afterwards, when enfeebled and unable to defend himself, again in
the stomach, both wounds being necessarily mortal, thereby
causing the direct and immediate death of said NICU DELA
MERCED.

Contrary to law.

Bataan, April 2, 2017


(SGD) Earl Estacio
Assistant City Prosecutor

Witnesses: 1. Ricky Flores 12 Del Monte Quezon City


2. Beth Tamayo 222 Mayon Quezon City

Bail Recommended: P10,000


CERTIFICATION

I hereby certify that the preliminary investigation in this case


has been conducted; I have examined the complaint and his
witnesses and on the basis of their sworn statements and other
evidence submitted before me there is reasonable ground to
believe that the offense charged has been committed; the accused
was informed of the complaint and was given an opportunity to
submit controverting evidence and that the filing of this
information was with the authority of the City Prosecutor.

Earl Estacio

SUBSCRIBED AND SWORN to before me this 3rd day of MARCH


2017 Balanga, Bataan.

Randy David
Administering officer
REPUBLIC OF THE PHILIPPINES
National Capital Judicial Region
REGIONAL TRIAL COURT
City of Manila
Branch 44

YRIZ TAMIE MARIANO,


Plaintiff,

-versus- CRIMINAL CASE NO. 24242


For: Violation of B.P Blg 22

SPINEL DECLARO,
Defendant.
x-----------------------------------------------------x

INFORMATION

The undersigned Assistant City Prosecutor, upon sworn


complaint originally filed by the offended party, accuses SPINEL
DECLARO for having violated B.P. Blg 22, committed as follows:
That on or about and during the period comprised between
January 2, 2016 and March 2017 in the City of Manila, Philippines,
within the jurisdiction of this court, the said accused, did then and
there draw and issue Check 87232-22 and Check 238498-92 dated
February 15, 2016, purportedly in payment of loan, which upon
presentment for clearing/collection was dishonored by the drawee
bank for the reason Account Closed/Drawn against Insufficient
Fund, and which check the accused failed to replace with cash
within 5 days from notice of dishonor.

Contrary to law.

Manila, 3 April 2017.


(SGD) Earl Estacio
Assistant City Prosecutor

Witnesses: 1. Ricky Flores 12 Del Monte Quezon City


2. Beth Tamayo 222 Mayon Quezon City

Bail Recommended: P10,000

CERTIFICATION
I hereby certify that the preliminary investigation in this case
has been conducted; I have examined the complaint and his
witnesses and on the basis of their sworn statements and other
evidence submitted before me there is reasonable ground to
believe that the offense charged has been committed; the accused
was informed of the complaint and was given an opportunity to
submit controverting evidence and that the filing of this
information was with the authority of the City Prosecutor.

Earl Estacio

SUBSCRIBED AND SWORN to before me this 3rd day of MARCH


2017 Manila, Philippines.

Randy David
Administering officer
REPUBLIC OF THE PHILIPPINES
National Capital Judicial Region
REGIONAL TRIAL COURT
City of Manila
Branch 44

PEOPLE OF THE PHILIPPINES,


Plaintiff,

-versus- CRIMINAL CASE NO. 24242


For: Murder

EARL ESTACIO,
Defendant.
x-----------------------------------------------------x

MOTION TO QUASH

Defendant thru counsel, and unto this Honorable Court,


moves to quash the information filed against the said defendant
on the following grounds:

1. That the criminal liability of the defendants has been


extinguished;

2. That the defendant is in jeopardy of being convicted of


the offense charged.

ARGUMENTS

a) That the criminal liability of the defendant has been


extinguished.
(Here state whether such extinction of criminal liability is
founded on amnesty, pardon or marriage of the offender with the
offended party in the cases where such pardon or marriage
extinguishes criminal liability, prescription of offenses or the
penalty, and the facts constituting such extinction)
b) That the defendant is in jeopardy of being convicted of
the offense charged.
(Here state, among others, the crimes under which the
name of the court in which he was in jeopardy, and the date and
place of such jeopardy)

PRAYER

WHEREFORE, in view of all the foregoing, it is respectfully


prayed that the above-entitled information be quashed, and the
defendant be discharged.
Other just and equitable reliefs are also prayed for.

Manila for Las Pinas City, November 22, 2007.

Demetrio Sandoval
Counsel for Defendant
4th floor, Madrigal Tower, Madrigal
Business Center, Alabang,
Muntinlupa City
Attorneys Roll No. 2324
IBP 2324-01/03/08 Muntilupa
PTR 4232-01/03/08 Muntilupa
MCLE No. 23242-Nov. 17, 2007

REQUEST FOR AND NOTICE OF HEARING

The Branch Clerk of Court


Regional Trial Court
Branch 24, Las Pinas City

Please submit the foregoing Motion to the Court for its


consideration and approval immediately upon receipt hereof and
kindly include the same in the courts calendar for hearing on
November 29, 2007 at 8:30 in the morning.

Demetrio Sandoval
Counsel for Defendant

Atty. Conrado Manuel


Counsel for Plaintiff
2176 Alabang-Zapote Road,
Las Pinas City

Please take notice that counsel has requested to be heard on


November 28, 2007 at 8:30 in the morning.

Demetrio Sandoval
Counsel for Defendant

EXPLANATION OF SERVICE

Copy of the motion was served to the defendant by registered


mail due to time and distance constraints, and for lack of the
undersigneds staff who can serve the same in person.

Demetrio Sandoval

CC: Atty. Conrado Manuel


Counsel for Plaintiff
2176 Alabang-Zapote Road,
Las Pinas City
REPUBLIC OF THE PHILIPPINES
National Capital Judicial Region
REGIONAL TRIAL COURT
City of Manila
Branch 44

PEOPLE OF THE PHILIPPINES,


Plaintiff,

-versus- CRIMINAL CASE NO. 24242


For: Murder

EARL ESTACIO,
Defendant.
x-----------------------------------------------------x

PETITION FOR BAIL

Defendant, in the above-entitled case, thru counsel, unto


this Honorable Court, respectfully states:

1. That the defendant is in custody for alleged commission


of a capital offense;

2. That no bail has been recommended for his temporary


release, on the assumption that the evidence of guilt is strong;

3. That the burden of showing that evidence of guilt is


strong is on the prosecution, and unless this fact is satisfactorily
shown, the defendant may be bailed at the courts discretion.

WHEREFOR, upon prior notice and hearing, it is respectfully


prayed that the defendant be admitted to bail in such amount as
this Honorable Court may fix.

Manila, Philippines. 3 April 2017.

Demetrio Sandoval
Counsel for Defendant
4th floor, Madrigal Tower, Madrigal
Business Center, Alabang,
Muntinlupa City
Attorneys Roll No. 2324
IBP 2324-01/03/08 Muntilupa
PTR 4232-01/03/08 Muntilupa
MCLE No. 23242-Nov. 17, 2007

REQUEST FOR AND NOTICE OF HEARING


The Branch Clerk of Court
Regional Trial Court
Branch 24, Las Pinas City

Please submit the foregoing Motion to the Court for its


consideration and approval immediately upon receipt hereof and
kindly include the same in the courts calendar for hearing on
November 29, 2007 at 8:30 in the morning.

Demetrio Sandoval
Counsel for Defendant

Atty. Conrado Manuel


Counsel for Plaintiff
2176 Alabang-Zapote Road,
Las Pinas City

Please take notice that counsel has requested to be heard on


November 28, 2007 at 8:30 in the morning.

Demetrio Sandoval
Counsel for Defendant

EXPLANATION OF SERVICE

Copy of the petition was served to the defendant by registered


mail due to time and distance constraints, and for lack of the
undersigneds staff who can serve the same in person.

Demetrio Sandoval

CC: Atty. Conrado Manuel


Counsel for Plaintiff
2176 Alabang-Zapote Road,
Las Pinas City
Republic of the Philippines
National Capital Judicial Region
REGIONAL TRIAL COURT
Branch 55, Quezon City

People of the Philippines,


Plaintiff,

- Versus - Criminal Case: 1234


For: Libel

Dr. Alicia Santos and Fr. Rolly Dela Vega,


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

MOTION TO DEFER ARRAIGNMENT AND TO SUSPEND


PROCEEDING

The accused, thru counsel, states that:

1. The above entitled case is set for arraignment on June 12,


2016 at 9:00 in the morning.

2. The basis in filing the present information is the Resolution of


the Office of the City Prosecutor of Quezon City dated
February 27, 2016 and the order dated March 25, 2016.

3. On May 20, 2016, the accused filed a Petition for Review of


the said resolution before the Department of Justice, and
which petition for Review is still pending for resolution.

4. In order not to render the Petition for Review moot and


academic, and in consonance with the provision of Sec. 11,
Rule 116 of the Revised Rules of Criminal Procedure, accused
respectfully moves that his arraignment schedule on June 12,
2016 be deferred or suspended and the proceedings of the
above-entitled case be held in abeyance until the final
resolution of the Petition for Review;

5. The present motion is filed not for the purpose of delaying


early disposition of the case but to secure the accused hasty,
malicious and oppressive prosecution, and to protect him
from and open and public accusation of crime, expense and
anxiety of a public trial and also to protect the State from
useless and expensive trial.
Accordingly, premises considered, and in the interest of
justice, it is respectfully asked that the arraignment of the accused
set on June 12, 2016 and the proceedings in the present case be
deferred and suspended until the final resolution by the
Department of Justice of the Petition for Review.

Other reliefs just and equitable are likewise prayed for.

Quezon City, 26 May 2016.

Atty. Rodrigo Duterte


Counsel for the Accused
IBP 23232/Quezon City/ 1-1-11
Roll 2342432
PTR No. 232323/QC/1-1-11
MCLE Comp No. 23234

Notice and Copy Furnished:

Atty. Chato Cabigas


Clerk of Court
Regional Trial Court
Branch 55, Quezon City

Office of the City Prosecutor


Quezon City

Please be notified that the foregoing motion is set for


hearing on June 2, 2005, Friday at 2:00 oclock in the afternoon.

Rodrigo Duterte

EXPLANATION OF SERVICE

The foregoing motion was not served personally to the Clerk


of Court and for the private complainants and service by registered
mail was resorted due to distance and lack of manpower and
thereby rendering personal service inconvenient and impracticable.
Republic of the Philippines
NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
Branch 33, Cebu City

Jose Martin Ramirez,


Plaintiff,

- Versus - Civil case: 8945


For: Sum of Money with
Damages

Spouses Rodrigo and Lourdes Eala


Respondent.

x--------------------------x

EX PARTE MOTION TO SET THE CASE FOR PRE-TRIAL


CONFERENCE

Plaintiff, thru counsel, states:


1. That the records of the case will show that the defendant
had already filed his answer and no subsequent pleadings
was filed;

2. That being the last pleading, the case should already be set
for pre-trial conference pursuant to Sec. 1, of Rule 18 of
the 1997 Rules of Civil Procedure.

Accordingly, premises considered, it is requested to this Court


that the above entitled case be set for pre-trial conference.

Other reliefs just and equitable are likewise prayed for.

February 26, 2016, Cebu City.

Atty. Jason B. Evangelista


Counsel for Plaintiff
Roll of Attorney 72727
IBP No. 88282/ 11-11-16
PTR No. 202020/ 11-11-16
MCLE No. 2424/ 05-30-14

Notice and Copy furnished:

Atty. Peter Pan


Counsel for Defendant
Suite 123 Linden Suites Tower
Ortigas St., Pasig City

The undersigned shall submit the foregoing motion for the Courts
resolution on 15 March 2016, Wednesday at 2:00 oclock in the
afternoon.

Jason B. Evangelista

EXPLANATION OF SERVICE

The foregoing motion was not served personally to the Clerk


of Court and for the private complainants and service by registered
mail was resorted due to distance and lack of manpower and
thereby rendering personal service inconvenient and impracticable.
REPUBLIC OF THE PHILIPPINES
National Capital Judicial Region
REGIONAL TRIAL COURT
City of Manila
Branch 44

PEOPLE OF THE PHILIPPINES,


Plaintiff,

-versus- CRIMINAL CASE NO. 24242


For: Murder

EARL ESTACIO,
Defendant.
x-----------------------------------------------------x

MOTION TO REDUCE BAIL

Accused, thru counsel, by way of a special appearance solely


for this purpose, respectfully alleges:

1. That the accused has been charged with Murder and that
the bail for his provisional release has been set at P50,000.00;

2. That the accused is a poor fellow of very limited means


such that it is impossible for him to pay the full amount of his bond
and is therefore constrained to request for a reduction of the
amount of bail;

3. That it would be advantageous to everyone if he be given


temporary liberty thereby allowing him to continue with his gainful
employment and as head of the family with three dependents;

4. As such, accused appeals to the mercy and compassion of


this Honorable Court and respectfully requests that the bail be
reduced to P20,000.00;
5. That this motion for reduction of bail is being filed without
prejudice to any other remedy which may be available to the
accused and that the accused expressly reserves the right to
question the legality of the issuance of the search warrant or his
warrantless arrest if the circumstances would so warrant.

WHEREFORE, accused respectfully prays that his bail be


reduced to P20,000.00

Other relief just and equitable are likewise prayed for.

Manila, Philippines. 3 April 2017.


Demetrio Sandoval
Counsel for Defendant
4th floor, Madrigal Tower, Madrigal
Business Center, Alabang,
Muntinlupa City
Attorneys Roll No. 2324
IBP 2324-01/03/08 Muntilupa
PTR 4232-01/03/08 Muntilupa
MCLE No. 23242-Nov. 17, 2007

REQUEST FOR AND NOTICE OF HEARING

The Branch Clerk of Court


Regional Trial Court
Branch 24, Las Pinas City

Please submit the foregoing Motion to the Court for its


consideration and approval immediately upon receipt hereof and
kindly include the same in the courts calendar for hearing on
November 29, 2007 at 8:30 in the morning.

Demetrio Sandoval
Counsel for Defendant

Atty. Conrado Manuel


Counsel for Plaintiff
2176 Alabang-Zapote Road,
Las Pinas City

Please take notice that counsel has requested to be heard on


November 28, 2007 at 8:30 in the morning.

Demetrio Sandoval
Counsel for Defendant

EXPLANATION OF SERVICE

Copy of the motion was served to the defendant by registered


mail due to time and distance constraints, and for lack of the
undersigneds staff who can serve the same in person.

Demetrio Sandoval

CC: Atty. Conrado Manuel


Counsel for Plaintiff
2176 Alabang-Zapote Road,
Las Pinas City