REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT OF BATANGAS

FOURTH JUDICIAL REGION
BRANCH 5
Lemery, Batangas

THE PEOPLE OF THE PHILIPPINES,

Plaintiff, CRIMINAL CASE NO.
36-2018

-versus-

ALAN DAVIDSON ALMENDRAS y

SANDICON,
Accused.
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MANIFESTATION AND MOTION TO SET

FOR PLEA BARGAINING

COMES NOW ACCUSED through counsel in the above-

entitled case and to this Honorable Court, most respectfully
avers:

1. It is a well settled principle that “plea bargaining is

to be encouraged because the chief virtues of the
system – speed, economy, and finality – can benefit
the accused, the offended party, the prosecution, and
the court”;

2. That the accused would like to avail of the said plea

bargaining and is willing to enter a plea of guilty for a
lesser offense;

3. That for such purpose, the accused moves to submit

and make himself available before this Honorable Court
where his presence is indispensable on a date
convenient to the calendar of the court;

4. Accused, thru undersigned counsel respectfully begs

the kind indulgence of this Honorable Court to give due
course to the instant motion.

Page 1 of 3
Crim. Case No. 36-2018
MANIFESTATION AND MOTION TO SET FOR PLEA BARGAINING
 PREMISES CONSIDERED, it is so respectfully prayed
for that this case be set on a date convenient to the calendar
of the court for purposes of plea bargaining.

Batangas City for Lemery, Batangas, 10 July 2018.

ROBERTO IÑIGO D. SANCHEZ

Counsel for the Accused
Zenaida Arcade, 43 M.H. Del Pilar St., Batangas City 4200
PTR No. 3025885 01.08.2018 Bats. City
IBP No. 1086954 01.08.2018 Bats. City
Roll No. 61644
MCLE Compliance Certificate No. V-0026006
valid until April 14, 2019
Telephone No. (043) 728 0002
ridslawoffice@gmail.com
srtclawoffice@gmail.com

Conformity:

ALAN DAVIDSON ALMENDRAS y SANDICON

Accused

NOTICE

OFFICE OF THE PROVINCIAL PROSECUTOR

Hall of Justice
Lemery, Batangas

THE CLERK OF COURT

RTC Branch 5
Lemery, Batangas

G R E E T I N G S:

Please submit the foregoing motion to the Honorable

Court immediately upon receipt hereof.
Page 2 of 3
Crim. Case No. 36-2018
MANIFESTATION AND MOTION TO SET FOR PLEA BARGAINING
 ATTY. ROBERTO IÑIGO D. SANCHEZ

Copy Furnished:

OFFICE OF THE PROVINCIAL PROSECUTOR

Hall of Justice
Lemery, Batangas

Page 3 of 3
Crim. Case No. 36-2018
MANIFESTATION AND MOTION TO SET FOR PLEA BARGAINING