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Republic of the Philippines

6TH JUDICIAL REGION


Regional Trial Court
Branch 32
Iloilo City

PEOPLE OF THE PHILIPPINES


Complainant,

-versus- For: Grave Threats


Article 282 of the
Revised Penal Code
PETER P. URSULA
Accused.

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

I N F O R M A T I ON

MOTION TO DISMISS

NOW COMES the Accused, by his undersigned attorney, to this


Honorable Court and respectfully moves that the complaint be dismissed on
the ground of lack of jurisdiction under BP. 129.

ARGUMENTS

Batas Pambansa Bilang 129 of the Judiciary Recognization Act


provides for the jurisdiction of courts in the Philippines. The complaint for
the allege commission Grave Threats against, Accused Peter P. Ursula, as
provided by law, is under the jurisdiction of the Regional Trial Court in
which the Complainant erred by submitting aforementioned complaint in the
Municipal Circuit Trial Court of Iloilo City. This error in the jurisdiction of
the case sufficiently renders the dismissal of the complaint.

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PRAYER

WHEREFORE, Accused, Peter P. Ursula, respectfully prays that, the


complaint be dismissed.

Iloilo City, Iloilo, Philippines January 14, 2023

ATTY. ANDREA B. DELOVIAR


Counsel for Petitioner
Deloviar Law Office, Jaro, Iloilo City
Notarial Commission valid until 12/31/2023
Roll of Attorney’s No. 743440
PTR No. 14344-000 Iloilo City 12/31/2023
IBP No. 123-54321 Iloilo City 12/31/2023
MCLE Compliance No. IV-01220-2020

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REPUBLIC OF THE PHILIPPINES)
PROVINCE OF ILOILO ) SS.
x----------------------------x

VERIFICATION

I, PETER P. URSULA, of legal age, Filipino, and address at San


Pedro, Jaro, Iloilo City Iloilo, Philippines after having been sworn into in
accordance with law, do hereby depose and state that:

1. I am the Accused in the above-caption Motion to Dismiss;


2. I have read the same and the contents thereof are known to me to be
true and correct based on my own personal knowledge and authentic
records attached in the Motion itself and made part of the records of this
Case.

IN WITNESS WHEREOF, I hereunto affix my signature this January


14, 2023 at Jaro, Iloilo City, Philippines.

PETER P. URSULA
Affiant
TIN NO. 1255-3420, Iloilo City

SUBSCRIBED AND SWORN TO BEFORE ME, this January 14,


2023 at Jaro, Iloilo City.

ATTY. ANDREA B. DELOVIAR


Counsel for Petitioner
Deloviar Law Office, Jaro, Iloilo City
Notarial Commission valid until 12/31/2023
Roll of Attorney’s No. 743440
PTR No. 14344-000 Iloilo City 12/31/2023
IBP No. 123-54321 Iloilo City 12/31/2023
MCLE Compliance No. IV-01220-2020

Doc. No. 7;
Page No. 3;
Book No. 1;
Series of 2023
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