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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
FIRST JUDICIAL REGION
BRANCH ___
________________, ILOCOS NORTE

PEOPLE OF THE PHILIPPINES,

Plaintiff,
-versus-
Crim. Case No. _________
BUGEN, ET. AL.,
Accused.
x----------------------------------------------------x

MOTION FOR LEAVE OF COURT

TO FILE DEMURRER TO EVIDENCE
 
Accused Zal MASAN, by the undersigned counsel and to this
Honorable Court, most respectfully avers:

1. That this Honorable Court had already made a ruling on the

prosecution’s Formal Offer of Evidence;

2. That the prosecution’s evidence is inherently weak,

unsubstantiated, and insufficient to prove the guilt of accused Zal
masan beyond reasonable doubt;

3. That with all due respect, it is necessary for the defense (to be
allowed by this Honorable Court to file Demurrer to Evidence
WITH LEAVE OF COURT to be able to point out in detail the
weakness of the prosecution’s evidence necessitating the
dismissal of the case against herein said accused and so as not to
further waste the precious time of this court.

WHEREFORE, premises considered, it is most respectfully prayed of

this Honorable Court that the instant Motion be granted, allowing
accused Zal masan thru counsel to file WITH LEAVE OF COURT
DEMURRER TO EVIDENCE.

Other reliefs, just and equitable under the premises, are likewise
prayed for.

San Juan, Ilocos Sur for ____________, Ilocos Norte.

_______________________________.
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MBS
For Accused

The Clerk of Court

Regional Trial Court
Branch _________, Ilocos Norte

GREETINGS:
Please submit the foregoing Motion on ___________________ for the
kind consideration and approval of the Honorable Court. Thank you.

MBS

Copy Furnished:

The Office of the City Prosecutors

___________, Ilocos Norte