Republic of the Philippines

REGIONAL TRIAL COURT

Third Judicial Region
Malolos City
-BRANCH ----

PEOPLE OF THE PHILIPINES,

-versus- Criminal Case Nos.

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Accused.
X------------------------------------------X
MOTION TO ALLOW ACCUSED
TO PLEAD GUILTY TO A LESSER OFFENSE
ACCUSED, wwwww, assisted by the Public Attorney's Office, and unto
this Honorable Court, most respectfully submits the instant motion based on
the following presentation:

1. Accused pleaded “NOT GUILTY” to the charge of violation of Sections

5 and 11, Article II, Republic Act (“R.A.”) No. 9165;

2. In view of the declaration of Section 23, Article II, R.A. No. 9165 as
unconstitutional in the case of Estipona, Jr. vs Lobrigo, et. al.1, accused
respectfully moves that he be allowed to withdraw his previous plea and
plead anew to the lesser offense as follows:

Case Number From: To:

Violation of Sec. 5, Article II, Violation of Sec. 12, Article
R.A. No. 9165 II, R.A. No. 9165
Violation of Sec. 11, Article II, Violation of Sec. 12, Article
R.A. No. 9165 II, R.A. No. 9165

in accordance with Administrative Matter No. 18-13-16-SC (Adoption of the

Plea Bargaining Framework in Drug Cases).

WHEREFORE, premises considered, it is most respectfully prayed of

the Honorable Court that the accused be allowed: (A) to withdraw his
previous plea; and (B) to enter new plea as stated above.

Other just and equitable reliefs are likewise prayed for.

Malolos City, Bulacan. 29 June 2018.

Conforme: (See attached Annex)

1
G.R. No. 226679, 15 August 2017