Republic of the Philippines

REGIONAL TRIAL COURT

Third Judicial Region
Branch 88
Baloc, Sto. Domingo, Nueva Ecija

PEOPLE OF THE PHILIPPINES,

Plaintiff,

- versus - CRIMINAL CASE NO. 1991-2011 (SJC)

FOR : Qualified Theft

NELSON VENTURINA y Andres

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

VERY URGENT MOTION TO ESCORT ACCUSED FOR

HOSPITAL CONFINEMENT

WITH ALL DUE RESPECT

ACCUSED, thru the undersigned counsel, most courteously prays that an
Order be issued to the Warden of BJMP San Jose City to escort herein accused
who was previously diagnosed with Cerebrovascular Disease and Type 2 Diabetes
mellitus for hospital confinement, and in support thereof, alleges that:
The accused is already 49 years old, and is suffering from right side body
weakness, high blood pressure, and slurring of speech upon admission at San Jose
City General Hospital on September 16, 2018 and was confirmed by CT Scan
through Rafael S. Joson, MD, FPCR, FCTMRISP of Heart of Jesus Hospital.
Attached hereto are copies of the aforementioned Hospital Abstract and the CT-
Scan report as Annexes “1” and “2”.
In the past few months, the accused’s health is degrading and his agony
worsened as he consistently suffers from headache, dizziness, and overall
weakness of the body due to high blood pressure.
Life and health of a person are still the paramount considerations, and the
herein accused is charged with a non-bailable offense, but he is still presumed

Very Urgent Motion to Escort Accused for Hospital Confinement

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innocent until proven guilty beyond reasonable doubt. His right to life could not
be impaired by reason of the instant case and his continuous confinement in a
regular jail facility would definitely endanger his life. Thus, the defense cannot
assure that he could live through his trial. Likewise, the confinement of the
accused in a hospital will address the objective of the prosecution ‘in seeing to it
that he will face trial and not abscond or be exposed to unnecessary risks’
(SANDIGANBAYAN’s Resolution on Juan Ponce Enrile’s Motion for Hospital
Detention).
Rest assured, that he believes that he is innocent of the crime charged and he
is willing to face the accusations against him in court. He is already of old age
with serious health problems such that there would be no risk of flight if the instant
motion be granted. Lastly, accused is willing to shoulder all the expenses of the
said confinement at a hospital.
In view thereof, in the pursuit of the HIGHER JUSTICE, it most respectfully
prayed that an order be issued for the Warden of BJMP San Jose City to escort the
accused for his confinement as soon as practicable.

A GENERAL PRAYER JUST AND EQUITABLE IS LIKEWISE

PRAYED FOR.
RESPECTFULLY SUBMITTED this 10th day of October 2018 hereat
Science City of Muñoz, Nueva Ecija.

ATTY. THRISTAN B.ESCUDERO

Roll No. 49000
IBP Receipt No. 1065081; 01/04/2018
PTR No. 4964596; 01/05/2018
MCLE Compliance No.IV-0023377
03 August 2016
nd
Address: 2 Floor Wisco Building, T. Delos Santos St.
Science City of Muñoz, Nueva Ecija
CP No. 0917-804-5830

THE CLERK OF COURT

RTC-Branch 38
Baloc, Sto. Domingo

Very Urgent Motion to Escort Accused for Hospital Confinement

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Greetings:

In view of the urgent nature of the instant motion, please submit the
foregoing motion for the kind consideration and approval of the Honorable Court
as soon as possible.

Atty. T.B. Escudero

Copy furnished: (via personal service)

Office of the City Prosecutor

San Jose City

Very Urgent Motion to Escort Accused for Hospital Confinement

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