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Sample Motion To Quash Information
Sample Motion To Quash Information
-Versus-
Criminal Case No.00-12773-13 &12774-13
FOR : QUALIFIED THEFT
EMELITA C. MAGRACIA,
HERMENLYN D. MONTOYA,
ELSA BULAHAN VALLAR,
DELMA GATOC,
JEFFERSON FERRER TIAUZON,
NOLLY BOY HALIM,
ANITA CASTILLO,
LUZ SIPAGAN,
ANNIE ARIOLA &
TESS LIMPIN,
Accused
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Prosecutor, accused herein were indicted for qualified theft, an
offense that is way different or in contrast to the offense
charged.
7. All told, the accused herein respectfully submits that since the
facts accrued by the complainants do not at all show criminal
liability and the resolution of the City prosecutor taking its
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whole context does not admit that the crime of qualified theft
was committed. If is therefore but imperative that the
information be quashed not only for lack of probable cause but
clearly the facts as shown does not constitute an offense.
Respectfully Submitted,
Copy furnished;
Apolinar S. Caparal
Vempauljor Corp, KM 29, Aguinaldo Hi-way,
Salitran 2, Dasmarinas City, Cavite