Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
Branch 22, Davao City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

CRIMINAL CASE No. 00937

-versus-
FOR: LIBEL

BRUNO MARS
Accused.

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

MOTION TO QUASH SEARCH WARRANT

The Accused, by counsel, respectfully moves for the quashal of

Search Warrant No. 7777 issued by this Honorable Court on and dated 20
February 2020 based on the following considerations:

1. Rule 126, Sec. 10 or the Revised Rules of Court provides expressly

that a search warrant shall be valid for ten (10) days from its date and that
thereafter, it shall be void.

2. Search Warrant No. 7777 is dated 20 February 2020. It was served

on the accused on 2 March 2020, the 11 th day from its date; this is certified
to by the Sworn Inventory and Return executed by Major Pam Paran, the
leader of the searching team (a copy of which is already part of the
records). A search was made on the same day, 2 March 2020; pursuant to
said search, certain objects were seized and delivered to the court. Under
the law, the Search Warrant is void and must, thus, be quashed.

PRAYER

WHEREFORE, it is respectfully prayed that Search Warrant No. 7777

be QUASHED and all objects seized under its purported authority be
declared INADMISSIBLE under the exclusionary rule in Article III, Section
3(2) in relation to section 2 of the 1987 Constitution.
 City of Davao. March 14, 2020.

VILLARIN LAW
Unit 11 & 12,City Triangle Corporate Center,
CM Recto St., Davao City

By:

ATTY. PAULO JOSE S. VILLARIN

Counsel of the Accused
Roll of Attorneys No. 696969
PTR No. 69669, 4-24-20, Davao City
IBP No. 5559, 4-24-20, Davao City
MCLE Compliance No. VII-0220293; 4-19-19
Valid until April 14, 2022
Ecoland, Davao City

Copy furnished:

Atty. Lyndzelle Ramona Irvina Olaco VIII

Door 12 , 2NE1 Compound, Alpha Street,
Matina, Davao City
NOTICE
The Branch Clerk of Court
Regional Trial Court
Branch 22, Davao City

Please set the foregoing Motion for the consideration and approval
of the Honorable Court on March 18 at 8:30 a.m., without appearance of,
or further arguments from, counsel.

PAULO JOSE S. VILLARIN

Counsel for the Plaintiff

Atty. Lyndzelle Ramona Irvina Olaco VIII

Door 12 , 2NE1 Compound, Alpha Street,
Matina, Davao City

Please take notice that the foregoing Motion will be set for the
consideration and approval of the Honorable Court on March 18 2020 at
8:30 a.m., without appearance of, or further arguments from, counsel

PAULO JOSE S. VILLARIN

Counsel for the Plaintiff