Motion For Reinvestigation

REPUBLIC OF THE PHILIPPINES
DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
LAS PIÑAS CITY, METRO-MANILA
PERLA EJERCITO MA. ASUNCION QUIOGUE,

Complainant,
- versus - I.S. NO.05-1077
EDUARDO SANCHEZ, ET AL.,

Respondent.
x--------------------------x
EX PARTE MOTION
TO REOPEN PRELIMINARY INVESTIGATION
AND TO ADMIT REPLY AFFIDAVIT
HEREIN RESPONDENTS, and unto this Honorable Office, most respectfully state,
THAT:
1. That last August 1, 2005, the above-entitled case was set for hearing before Honorable
State Prosecutor Mario Mangrobang;
2. That on that date respondents were in the hospital to attend to the sick mother of
Eduardo who was in the Philippine General Hospital that time;
3. That respondent Eduardo tried to come to the Office of the Honorable State Prosecutor
but he arrived late and was informed that the case was already submitted for resolution;
4. That we intend to submit our Counter Affidavit, hence we respectfully move that the
case be reopened for preliminary investigation, and that the herein attached Reply Affidavit be
admitted in the high interest of justice;
WHEREFORE, it is most respectfully prayed of the Honorable Prosecutor that the case
be reopened for preliminary investigation and that the attached Reply Affidavit be admitted;
Other just and equitable reliefs are likewise prayed for.
Las Piñas City, Metro-Manila, August 4, 2005.
EDUARDO SANCHEZ CRISTINA SANCHEZ
CRISTELA SANCHEZ
Copy Furnished:
Ma. Asuncion Quiogue

Door 1 Cor. Don Benito St.,
Pamplona Village, Pamplona 1
Las Pinas
RHEA PALTEP,
Complainant,
- versus - I.S. No. 04-2751
SANCHO PALTEP,
Respondent.
x-----------------------x
MOTION TO REOPEN
PRELIMINARY INVESTIGATION
AND TO ADMIT THE ATTACHED
AFFIDAVIT OF DESISTANCE
ACCUSED, assisted by the undersigned Public Attorney, and
unto this Honorable Court, most respectfully state:
1. That herein accused stand charged of the crime of Physical
Injuries in relation to R.A. 7610;
2. That the Preliminary Investigation of the above-mentioned
case was already terminated and is now submitted for resolution;
3. That the complainant had already executed an Affidavit of
Desistance and hereto attached as Annex “A”;
WHEREFORE, in the interest of justice it is most respectfully
prayed that the conduct of preliminary investigation be reopened
and to admit the attached Affidavit of Desistance.
Las Piñas City, Metro-Manila.

March 16 2005.
PUBLIC ATTORNEY’S OFFICE
Las Piñas City District Office
3rd Floor, Hall of Justice
Las Piñas City, Metro Manila
BY:
EUGENE C. CABARDO
Public Attorney II
NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH 199
PEOPLE OF THE PHILIPPINES,

Plaintiff,
- versus - CRIM. CASE NO. 04-0841
ALFREDO RABE III y GARCIA,

Accused.
x-----------------------x
MOTION FOR REINVESTIGATION
ACCUSED, assisted by the undersigned Public Attorney, and
unto this Honorable Court, most respectfully state:
1. That herein accused stand charged of the crimes of
“FRUSTRATED HOMICIDE”;
2. While accused was informed of his right to a preliminary
investigation during the inquest proceedings, he could not rightfully
exercise thereto, as he could not understand its legal implication;
3. It is only now that he was able to ask assistance from a
counsel relative to this case, and his counsel advise him to exercise
right to a preliminary investigation;

4. Further, herein accused only learned that the information was
filed against him last Monday September 27, 2004 when his father
informed him about such fact;
5. Since accused has not been arraigned, he could rightfully ask
for a preliminary investigation as it is a substantive right (Yusop vs.
Sandiganbaya, 352 SCRA 587);
6. That there were several eyewitneses namely ELSA
PLOMENTERA, victim’s girlfriend, REGINA PLOMENTERA,BABY
ARGANA,who were the companions of the victim-complainant and was
present at the time of the alleged incident who intimated their desire to
submit the necessary counter affidavit;
7. That these are vital witnesses and that their counter affidavits
will change the outcome of the case if submitted during the preliminary
investigation;
8. That in order not to waste the very precious time and efforts of
this Honorable Court in this case, it is but proper and appropriate that
“Re-Investigation” of these cases be conducted, hence, this Motion.
WHEREFORE, in the interest of substantial justice and to afford
accused of his right to Preliminary Investigation, it is most respectfully
prayed of this Honorable Court that this Motion for Re-investigation be
granted.
October 1, 2004.
BY:
EUGENE C. CABARDO
Public Attorney II
NOTICE OF HEARING
The Branch Clerk of Court

Las Piñas City, Metro-Manila
Greetings:
Please submit the foregoing Motion consideration and approval

by the Honorable Court immediately upon receipt hereof.
ATTY. EUGENE C. CABARDO
Copy Furnished:
Office of the City Prosecutor

Las Pinas City
BRANCH 200

Plaintiff,
MARITA ROSALES Y QUILATAN,

PERLITA PAREJA Y DELA CRUZ,
Accused.
x-----------------------x
ACCUSED, thru counsel, and unto this Honorable Court, most
respectfully state:
1. That herein accused stand charged of the crimes of “VIOLATION OF
SEC. 5, ART. II, R.A. 9165”;
2. While both accused were informed of their right to a preliminary
investigation during the inquest proceedings, they could not rightfully exercise
thereto, as they could not understand its legal implication;
3. It is only now that they were able to ask assistance from a counsel
relative to this case, and their counsel advise them to exercise right to a
preliminary investigation;
4. Since both accused has not been arraigned, they could rightfully ask
for a preliminary investigation as it is a substantive right (Yusop vs.
Sandiganbaya, 352 SCRA 587);

-2-
5. That in order not to waste the very precious time and efforts of this
Honorable Court in these cases, it is but proper and appropriate that “Re-
Investigation” of these cases be conducted, hence, this Motion.
WHEREFORE, in the interest of substantial justice and to afford both
accused of their right to Preliminary Investigation, it is most respectfully prayed
of this Honorable Court that this Motion for Re-investigation be granted.
February 26, 2004.
BY:
ROLITO A. ABING
Public Attorney II
NOTICE OF HEARING

Greetings:
Please take notice that the foregoing Motion shall be heard on March 3,
2004 at 2:00 o’clock in the afternoon for its consideration and approval by the
Honorable Court.
ATTY. ROLITO A. ABING

RTC-Branch 200
Greetings:
Kindly include in the calendar of this Honorable Court the foregoing

Motion for its consideration and approval on March 3, 2004 at 2:00 o’clock in
the afternoon.

BRANCH 200

Plaintiff,
MARITA ROSALES Y QUILATAN,

PERLITA PAREJA Y DELA CRUZ,
Accused.
x-----------------------x
SUPPLEMENTAL GROUNDS TO THE

respectfully state, that:
1. Accused, in asserting their right to a preliminary investigation would
like to emphasize that they were not assisted with counsel during the inquest
proceedings. In fact, they were not brought to the Public Attorney’s Office prior
to their inquest at the Prosecutor’s Office. Accused should have been assisted
with counsel because of the gravity of the offense levied against them.
Procedural requirements that during inquest proceedings, arrested persons
should be afforded with counsel should have not been brushed aside, taking
into account the non-bailable offense imputed against them. In fact, the waiver
against Article 125 of the Revised Penal Code would show that no counsel has
assisted both accused. Thus, there was procedural lapses during the inquest
proceedings;
2. Moreover, both accused only learned that an Information was filed
against them on February 24, 2004, after their relatives told them that a case
was indeed filed against them. Thus, this Motion for Reinvestigation was filed
within the 5-day reglementary period.

-2-
WHEREFORE, premises considered, it is respectfully prayed of this
Honorable Court that the instant case be remanded to the Prosecutor’s Office
for reinvestigation.
April 15, 2004.
BY:
ROLITO A. ABING
Public Attorney II
NOTICE OF HEARING

Greetings:
Please take notice that the foregoing Supplemental Grounds to the

Motion for Re-investigation shall be heard on April 20, 2004 at 1:30 o’clock in
the afternoon for its consideration and approval by the Honorable Court.

RTC-Branch 200
Greetings:

Supplemental Grounds to the Motion for Re-investigation for its consideration
and approval on April 20, 2004 at 1:30 o’clock in the afternoon.
Copy furnished:

Las Piñas City


Complainant,
- versus - I.S. NO. _________________
CAMANSAEL P. ARRO,
Respondent.
x--------------------------x
MOTION TO CONDUCT PRELIMINARY INVESTIGATION
WE, JOCELYN DR. ARRO and LIBERATO T. ARRO, JR., and unto this
Honorable Court, most respectfully state, THAT:
1. We are the first degree cousins of CAMANSAEL P. ARRO, who
charged before this Office for a crime of Theft committed against Puregold
Supermarket;
2. We just recently learned the said incident, and we would like to
inform this Honorable Office that the said person is insane;
3. We respectfully move that a preliminary investigation be conducted
on our cousin;
4. We are attaching herein a copy of our Affidavit to attest the fact that
our cousin is insane, and that he did not have any criminal intent to commit
the offense charged against him.
February 26, 2004.
BY:
ROLITO A. ABING
Public Attorney II
NOTICE OF HEARING

Greetings:
Please take notice that the foregoing Motion shall be heard on March 3,
2004 at 2:00 o’clock in the afternoon for its consideration and approval by the
Honorable Court.

RTC-Branch 200
Greetings:

Motion for its consideration and approval on March 3, 2004 at 2:00 o’clock in
the afternoon.

LAS PIÑAS CITY
EUSEBIO OBRERO y PEÑA,

Complainant,
- versus - I.S. NO. LP 04-0192
For: ATTEMPTED HOMICIDE
MANNY QUIMUEL y BRANZUELA
And JERRY BARRING y GOPIO
@ BOY EXPERT,
Respondent.
x - - - - - - - - - - - - - - - - - - - - - - - - -x
RESPONDENT JERRY BARRING y GOPIO, thru counsel, and unto this
Honorable Office, most respectfully states:
1. That on May 18, 2004, herein respondent, received a copy of the
Resolution of this Office impleading him for the crime of attempted murder
pursuant to a complaint filed by Eusebio Obrero Y Peña;
2. That herein respondent was not aware of the filing of this case against
him, as he was not able to receive any subpoena relative thereto. In fact the
Resolution was received by him only through a Barangay Tanod of Almanza I,
Las Piñas City;
3. That herein respondent is not in any way involve in the instant
complaint and he could very well prove that there is no probable cause to
implead him and chage him before the court. Thus, herein respondent prayed
that a reinvestigation be conducted on his favor ;
4. This motion is not intended to delay the progress of this case but
solely based on the grounds stated.

-2-
5. That in order not to waste the very precious time and efforts of this
Honorable Office, it is but proper and appropriate that a “Re-Investigation” be
conducted in this case.
WHEREFORE, in the interest of substantial justice and to afford herein
respondent of his right to Preliminary Investigation, it is most respectfully
prayed of this Honorable Office that this case be reinvestigated.
May 21, 2004.
BY:
ROLITO A. ABING
Public Attorney II
Copy furnished:
EUSEBIO P. OBRERO
Real St., Almanza I
Las Piñas City

BRANCH 200

Plaintiff,
ESTELITA VAPFLOR-PASCUAL,
Accused.
x-----------------------x
OMNIBUS MOTION TO WITHDRAW

PETITION FOR BAIL AND TO
REQUIRE PROSECUTION TO PRESENT
ITS MAIN EVIDENCE
respectfully states:
1. On November 3, 2004, the prosecution has offered its documentary
evidence relative to petition for bail filed by the accused;
2. Accused is withdrawing her Petition for Bail and would herein moves
that the prosecution be required to present its evidence in chief.
WHEREFORE, premises considered, it is respectfully prayed of this
Honorable Court that the Petition for Bail of the accused be considered
withdrawn and that the prosecution be required to present its main evidence.
Other just and equitable premises are likewise prayed for.
November 12, 2004.

-2-
BY:
ROLITO A. ABING
Public Attorney II
NOTICE & COPY FURNISHED
THE BRANCH CLERK OF COURT

RTC-Branch 200
HON. ALEXANDER SUAREZ

Greetings:
Please take notice that the foregoing Motion shall be heard on November
17, 2004 at 2:00 o’clock in the afternoon for its consideration and approval by
the Honorable Court.

Motion For Reinvestigation

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REPUBLIC OF THE PHILIPPINES

PERLA EJERCITO MA. ASUNCION QUIOGUE,

- versus - I.S. NO.05-1077

EDUARDO SANCHEZ, ET AL.,

Other just and equitable reliefs are likewise prayed for.

Las Piñas City, Metro-Manila, August 4, 2005.

EDUARDO SANCHEZ CRISTINA SANCHEZ

Ma. Asuncion Quiogue

- versus - I.S. No. 04-2751

ACCUSED, assisted by the undersigned Public Attorney, and

unto this Honorable Court, most respectfully state:

1. That herein accused stand charged of the crime of Physical

Injuries in relation to R.A. 7610;

2. That the Preliminary Investigation of the above-mentioned

case was already terminated and is now submitted for resolution;

3. That the complainant had already executed an Affidavit of

Desistance and hereto attached as Annex “A”;

WHEREFORE, in the interest of justice it is most respectfully

prayed that the conduct of preliminary investigation be reopened

and to admit the attached Affidavit of Desistance.

Las Piñas City, Metro-Manila.

PEOPLE OF THE PHILIPPINES,

ALFREDO RABE III y GARCIA,