For: VIOLATION OF SEC.

11 ARTICLE II OF
R.A. 9165
JUAN DELA CRUZ,
Accused.
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MEMORANDUM FOR THE ACCUSED

COMES NOW, the accused by the undersigned counsel and unto this
Honorable Court, most respectfully submit this Memorandum:

FACTS

“That on or before May 1, 2008, in the City of Iligan,

Philippines, and within the jurisdiction of this Honorable Court,
the said accused, without authority of the law, did then and there
willfully, unlawfully and feloniously have in his possession,
custody and control 9 plastic sachet of Methamphetamine
Hydrochloride weighing more or less 10.25 grams locally known
as “Shabu”. “

Contrary to and in violation of Section 11, Article II of

Republic Act 9165.

City of Iligan, May 5, 2008.

ISSUES
1. WHETHER OR NOT THE ARREST FOR THE ACCUSED IS VALID;
2. WHETHER OR NOT THE PROCEDURAL REQUIREMENTS OF
SECTION 21 WITH RESPECT TO PROCEDURAL AND DISPOSITION
OF CONFISCATED DRUGS WERE FOLLOWED.
3.