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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


FOURTH JUDICIAL REGION
BRANCH 1 – BATANGAS CITY

THE PEOPLE OF THE PHILIPPINES,


Plaintiff,

- versus – Criminal Case No. 18-23475


For: Rape
ROGELIO CASALLA FALTADO,
Accused.
x-------------------------------------------------x

MOTION TO ALLOW ACCUSED


TO UNDERGO MEDICAL EXAMINATION
COMES NOW, ACCUSED, through the undersigned counsel,
and unto this Honorable Court most respectfully states:

That accused is presently detained at the Batangas City Jail, Brgy.


Sico, Batangas;

That for the past few months, the accused has been consistently
suffering from discomfort which appears to be symptoms of Hernia;

That the defense does not want to compromise the health and
safety of our client. Hence, for medical reasons, we most
respectfully ask the kind indulgence of the Honorable Court and of
the Office of the Prosecutor that the accused be allowed to undergo
surgery at the Batangas Medical Center on or before 31 August
2018 to ensure his health and safety;

WHEREFORE, premises considered, it is most respectfully


prayed of this Honorable Court that this Motion be Granted.

Other reliefs, just and equitable under the premises are likewise
prayed for.

Batangas City, 28 August 2018.

PUBLIC ATTORNEY’S OFFICE


DEPARTMENT OF JUSTICE
BATANGAS DISTRICT OFFICE
HALL OF JUSTICE BUILDING
PALLOCAN, BATANGAS CITY
Counsel for the Accused

By:

MARIA MONICA PAMELA I. MENDOZA


Public Attorney I
Roll of Attorneys No. 68200
IBP No. 028210 / Makati / 01-17-18
MCLE Exemption for New Lawyers

NOTICE OF HEARING
The City Prosecutor
Batangas City

The Branch Clerk of Court


Regional Trial Court
Branch 1-Batangas City

GREETINGS:

Please submit the foregoing Urgent Motion to the Honorable


Court immediately upon receipt hereof.

MARIA MONICA PAMELA I. MENDOZA

Copy furnished:

Office of the City Prosecutor


Batangas City