REPUBLIC OF THE PHILIPPINES

National Capital Region

REGIONAL TRIAL COURT
Branch 170
Malabon City

PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 19-1397-MN

Plaintiff For: Violation of Section 12, Art. II
R.A. no. 9165

-versus-

FERDINAND BAISA y BASA

Accused.
x - - - - - - - - - - - - - - - - -- - - x

MOTION TO WITHDRAW APPLICATION FOR PROBATION

Accused FERDINAND BAISA y BASA, assisted by the PUBLIC
ATTORNEY’S OFFICE through the undersigned counsel, unto this Honorable Court,
most respectfully manifests the following:

1. That, Accused was convicted for the crime charged in a Decision dated
December 12, 2019. Accordingly, he was sentenced for an imprisonment of SIX MONTHS
AND ONE DAY TO ONE YEAR. He was also ordered to pay a fine of TEN THOUSAND
PESOS (P10,000.00) with subsidiary imprisonment in case of insolvency. When asked by
the Honorable Court if he is capable of paying the fine, he said no. Hence, the Court meted
him out an additional EIGHTEEN DAYS subsidiary imprisonment;

2. That, immediately thereafter, the Accused applied for probation;

3. That, to date, the Probation Office for Navotas and Malabon City has yet to act
on said application;

4. That, considering that the purpose for the application for probation could no
longer serve its use because it was already taken over by some events, i.e. the Accused
would have served his sentence in November 2020, he is now hereby withdrawing his
application for probation and will just serve the remaining period of imprisonment.

PRAYER

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

Honorable Court that the instant Motion be granted.
Other reliefs just and equitable under the premises are likewise prayed for.
Malabon City, Metro Manila,
22 October 2020.

PUBLIC ATTORNEY’S OFFICE

MALABON CITY DISTRICT
Counsel for Accused
No. 160 Gov. W. Pascual Avenue,
Tinajeros, Malabon City
Telephone No. 02-2857957
 By:

RAMIL M. COMENDADOR
Public Attorney II
Roll of Attorney No. 70262
MCLE Compliance No. VI-0004946
Valid Until April 14, 2022

NOTICE

ATTY. JESUS S. HERNANDEZ

Branch Clerk of Court
RTC Branch 170, Malabon City

G r e e t i n g s!
Immediately upon receipt hereof, please submit the foregoing Motion for
the consideration and approval of the Honorable Court.

RAMIL M. COMENDADOR

Copy furnished through email.

HON. FATIMA ANNE C. ZAMORA
Office of the City Prosecutor
Catmon, Malabon City