Republic of the Philippines

REGIONAL TRIAL COURT

11th JUDICIAL REGION
Branch 15
Davao City

People of the Philippines, Criminal Case No. 1234567

Plaintiff

~ versus ~ For: HOMICIDE

SPO1 Leo B. Escalante Jr., et. al.

Accused

x-------------------------------------------------x

URGENT MOTION
FOR ISSUANCE OF HOLD DEPARTURE ORDER

COMES NOW, the plaintiff, by the undersigned private counsel, with the
conformity of the public prosecutor and unto this Honorable Court,
respectfully moves for the issuance of a Hold Departure Order (HDO)
against the accused, and alleges that:

1. The accused is currently employed by the Philippine National Police

(PNP). In light of this ongoing case, a Memorandum was issued to the
accused stating that the he is “reinstated to Panabo City” until the
resolution of this case. Attached hereto is a copy of a Memorandum
and marked as Annex “A”;

2. The Memorandum was issued before the accused has submitted a

copy of his bail bond amounting to SIX HUNDRED THOUSAND
PESOS (P600,000.00). Attached hereto is a copy of the above-
mentioned bail bond marked as Annex “B”’;

3. In view of the above mentioned circumstances, A Watch List Order

(WLO) against the accused has been issued by the Department of
Justice (DOJ) upon application of the plaintiff attached and marked
hereto as Annex “C”;

4. Preventing the accused from leaving the country is proper considering

that the crime charged against him is a serious offense;
 5. All precautions should be observed to ensure proper dispensation of
justice.

WHEREFORE, premises considered, it is respectfully prayed that a Hold

Departure Order be immediately issues against the accused.

Davao City, Philippines, March 14, 2020.

ATTY. ERICK JAY N. INOK

Counsel for the Plaintiff
Notary Public / Roll of Attorneys No. 420696
Notarial Commission Serial No. 2019-420-2020
Commission Expires on December 31, 2020
IBP No. 030524; 01/10/2020; Davao City
PTR No. 1760152C; 01/04/2020; Davao City
MCLE Compliance No. VI–0012697 – 09/19/2019
Tel Nos. (082) 225-2066; (082) 241-2945
Email Address: ERICKSKIE23@yahoo.com
Legal Office, Commission on Audit R.O XI, Davao City

CONFORME:

ATTY. RODRIGO DUTERTE

Assistant City Prosecutor

2
 NOTICE OF HEARING
Atty. Salvador Pandesal
The Brach Clerk of Court
RTC Davao City, Branch 15

Atty. Rudy Deterty

For Accused Leo B. Escalante
13 Digong St, Maa, Davao City

Please take notice that the undersigned counsel will submit the
foregoing Motion for the consideration and approval of the Court on March
25, 2020 at 8:30 AM, with or without appearance of counsel.

Atty. Erick Jay N. Inok

Copy furnished:

Atty. Rudy Deterty Registry

Receipt._____________________
13 Digong St, Maa, Davao City Date._______________________________

EXPLANATION
(please disregard if served by personal service)

Due to lack of available office/messengerial personnel, and time

constraints, service by registered mail of this motion on the other parties
aforementioned were resorted to.

Atty. Erick Jay N. Inok