Republic of the Philippines

First Judicial Region

REGIONAL TRIAL COURT
BRANCH 1
San Fernando City, La Union

PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 9236

Plaintiff,
-versus- For

NATE CRUZ VIOL. OF SEC. 5 ART. 11

Accused. OF R.A. 9165

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MOTION TO PASS

ACCUSED, by and through the undersigned counsel and unto this Honorable
Court, most respectfully avers that:

1. Accused is presently detained at the San Fernando City Jail in Barangay

Camansi, San Fernando City, La Union;

2. Accused has been suffering from an ear infection for nearly three (3) weeks
now rendering him partially unable to hear. The current condition of his ear
necessitates urgent medical attention by a certified eye, ear, nose and throat
(EENT) specialist in order to alleviate the pain and discomfort that he is
presently experiencing and to prevent the same from worsening;

3. Accused, thus, begs the indulgence of the Honorable Court to allow him to
undergo medical examination at the Ilocos Training and Regional Medical
Center (ITRMC) in San Fernando City, La Union on September 6, 2017 at
2:00 o’clock in the afternoon with proper escort;

4. Accused will be attended by either Dr. Dela Cruz or Dr. Villanueva, the
accredited EENT specialists of the ITRMC. He shall shoulder all the expenses
appurtenant to such medical examination.

WHEREFORE, premises considered, it is most respectfully prayed unto this

Honorable Court that the accused be allowed to undergo medical examination at the
ITRMC in San Fernando City, La Union on September 06, 2017 at 2 o’clock in the
afternoon with proper escort.

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

San Fernando City, La Union, September 2, 2017.

PAULO DIAZ
Counsel for the accused
Roll No. 12345

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The Clerk of Court

RTC-Branch 1
San Fernando City, La Union

Greetings!

Please submit the foregoing motion for the consideration and approval of
the Honorable Court immediately upon receipt hereof

PAULO DIAZ

Copy furnished:

Office of the Provincial Prosecutor

San Fernando City, La Union