Republic of the Philippines

REGIONAL TRIAL COURT

7TH Judicial Region
City of Cebu
Branch 57

PEOPLE OF THE PHILIPPINES,

Plaintiff, CRIM. CASE NO. R-CEB-18-05466-CR

-versus- For: Viol of Sec.11, Art. II, RA 9165

RACHEL EVE FERNAN HERNANE,

Accused.
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MOTION TO DISCHARGE THE ACCUSED FROM

THE IN-PATIENT TREATMENT AND REHABILITATION PROGRAM

Accused, assisted by the PUBLIC ATTORNEY’S OFFICE, unto this Honorable

Court, most respectfully moves that:

1. On January 8, 2020, this Honorable Court issued and Order for the In-
patient treatment and rehabilitation of the accused at DOH Treatment
and Rehabilitation Center Cebu City, Jagobiao, Mandaue City in
accordance with the recommendation of Dr. Jasmin T. Peralta;

2. Accordingly, accused was admitted to the above-mentioned rehab

center on February 18, 2020;

3. Accused has been under treatment and rehabilitation for more than
six (6) months and her family had paid more or less Php29,000.00 for her
treatment and rehabilitation;

4. However, until today the said rehab center has yet to submit its
progress report of the accused’s treatment and rehabilitation;

5. The family of the accused cannot anymore defray the expenses of her
in-patient treatment and rehabilitation hence;

6. Accordingly, accused hereby seeks the kind indulgence of this

Honorable Court, that she be discharged from the said In-patient
treatment and rehabilitation and allow her to continue the said
treatment and rehabilitation in an out-patient manner.

PRAYER

WHEREFORE, in view of the foregoing, it is most respectfully prayed of this

Honorable Court, that she be immediately discharged from the said In-patient
treatment and rehabilitation and allow her to continue the said treatment and
rehabilitation in an out-patient manner.
 Other reliefs which are just and equitable under the premises are likewise
prayed for.

Respectfully submitted. October 15, 2020. Cebu City, Philippines.

PUBLIC ATTORNEY’S OFFICE

(Counsel for Accused)
3rd Flr., Taft Commercial Center, Metro Colon Carpark
Kalubihan, Cebu City

By:

JED CARLO S. LAZAGA

Public Attorney II
Roll No. 60047
IBP No. AR: 3417651, 1/06/2020, Cebu City
MCLE Compliance No. VI-0006349,
Valid Until April 14, 2022

REQUEST

Ms. Enid Joyce O. Cañon

Branch Clerk of Court
RTC 57, Cebu City

Hon. Benison Harayo

Resident Public Prosecutor
RTC-57 Cebu City

Dr. Jasmin T. Peralta

Chief of Hospital II
DOH TRC Cebu City

Please submit the foregoing Motion to the kind attention of the Honorable
Court for its consideration and approval immediately upon receipt sans
appearance of counsel.

Thank you very much.

Jed Carlo S. Lazaga

Copy furnished:

Hon. Benison Harayo

Resident Public Prosecutor
RTC-57 Cebu City
benison.harayo@gmail.com

Dr. Jasmin T. Peralta

Chief of Hospital II
DOH TRC Cebu City
cebu_trc@yahoo.com.ph