REPUBLIC OF THE PHILIPPINES

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
LAS PIÑAS CITY, METRO MANILA

SPO1 FRANCISCO AGANAN,

PO3 BENNIZER GONZALES,
PO1 DENNIS BORNILLA,
PO1 CORNELIO JACOB,
Complainants,

- versus - I.S. NO. ____________

FOR: Sec. 6 and 12, R.A. 9165

ADELAIDA CRISTOBAL y ZABLAN,

JAIME PEREZ y VILLANUS,
EDWARDO GUTIEREZ y ZABLAN,
Respondents.
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MOTION TO CONDUCT
PRELIMINARY INVESTIGATION

RESPONDENTS, ADELAIDA CRISTOBAL y ZABLAN, JAIME

PEREZ y VILLANUS, EDWARDO GUTIEREZ y ZABLAN by themselves,
unto this Honorable Office, most respectfully state, that:

1. Respondents herein were arrested for violation of R.A. 9165 and were subjected to
inquest investigation. However, herein respondents wanted to avail their procedural right to a
preliminary investigation.

2. Pursuant to the policy of the Prosecutor’s Office to resolve cases

on the merits thereof, there is a need to allow respondents and their
witnesses to file their Counter-Affidavit and Affidavits in order to hear the
sides and claims of both parties.

WHEREFORE, premises considered, it is respectfully prayed of this

Honorable Office that respondents be accorded with their right to
preliminary investigation.

Other just and equitable relief are likewise prayed for.

Las Piñas City, Metro-Manila

August 26, 2003.

ADELAIDA CRISTOBAL y ZABLAN JAIME PEREZ y VILLANUS
Respondent Respondent

EDWARDO GUTIEREZ y ZABLAN

Respondent