Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
BRANCH 11
Davao City

THE PEOPLE OF THE PHILIPPINES

CRIMINAL CASE NO. R-DVO-18-
-versus- 01411-CR

RICHARD LAPUT ESTUDILLO alias For: Violation of Sec. 26 in relation to Sec.

“RICHARD” and RYAN LAPUT 5 and 25 of Art. II of RA 9165
ESTUDILLO alias “RYAN”,
Accused.
x------------------------------------------------x
THE PEOPLE OF THE PHILIPPINES
CRIMINAL CASE NO. R-DVO-18-
-versus- 01412-CR

RYAN LAPUT ESTUDILLO alias For: Violation of Sec. 11, 2nd Par. Sub-Par.
“RYAN”, 3, in relation to Sec. 25, Art. II of RA 9165
Accused.
x------------------------------------------------x
THE PEOPLE OF THE PHILIPPINES CRIMINAL CASE NO. R-DVO-18-
01413-CR
-versus-
For: Violation of Sec. 28(e)(i) in relation to
RICHARD LAPUT ESTUDILLO alias Sec. 28(a) of RA 10591
“RICHARD”
Accused.
x--------------------------------------------------x

PETITION/APPLICATION FOR PROBATION

COMES NOW, Accused RICHARD LAPUT ESTUDILLO alias “RICHARD”

and RYAN LAPUT ESTUDILLO alias “RYAN”, through the undersigned counsel
and unto this Honorable Court, humbly and most respectfully applies for probation under
the provisions of Presidential Decree No. 968 as amended, and hereby avers that:

1. Premised from the records of this case, both accused applied for plea bargaining
to lesser offenses which was APPROVED by this Honorable Court.

2. Hence, a promulgation of judgment was made and embodied in the Order dated
August 28, 2018, which provides in its third paragraph, to wit:

Page 1 of 3
 “WHEREFORE, by accused own admission over the objection and non-
conformity of the Trial Prosecutor and the Arresting Officer, the court in the
exercise of its discretion in consonance with AM No. 18-03-16 SC, hereby
sentences accused Richard Laput Estudillo and Ryan Laput Estudillo to two
(2) counts of violation of Section 12 of Republic Act 9165 and hereby
sentenced to suffer imprisonment of Six (6) months and One (1) day as
minimum to Four (4) years as maximum and a fine of P25,000.00 each for
each of these two (2) cases.

Xxx xxx xxx.

Accused Richard Laput Estudillo is likewise sentenced to suffer imprisonment

of prision correccional and fine of P10, 000.00 as his penalty for pleading
guilty to the lesser offense of violation of Section 31 of Republic Act 1091.”

3. Verily, herein accused through the undersigned counsel are truly grateful to this
Honorable Court for approving accused’s application for plea bargaining.

4. More so, the crimes for which the accused were convicted were NOT offenses
against national security or public order.

5. Herein accused are “first-time offenders”, and have NOT been previously
convicted by final judgment of any offense punishable by imprisonment of not less
than one month and one day and/or fine of not less than two hundred pesos.

6. Accused also have NOT been previously placed on probation under the provisions
of Presidential Decree No. 968, otherwise known as the “Probation Law of 1976”,
as amended.

7. Accused has all the qualifications and none of the disqualifications to avail of the
benefits of the Probation Law. 

PRAYER

WHEREFORE, premises considered, it is humbly and most respectfully prayed of

this Honorable Court that the instant Petition/Application for Probation be referred to
the Parole and Probation Officer of Davao City for the requisite post-sentenced
investigation and thereafter, the application for probation be approved. 

OTHER RELIEFS, just and equitable, are likewise prayed for.

DONE this 6th day of September 2018, in Davao City, Philippines.

THE LAW FIRM OF TORREON AND PARTNERS

Door 201, LDL Commercial Bldg. Airport Road, Buhangin, Davao City

Page 2 of 3
 For the firm:

ATTY. ERICK JOHN S. CABUSLAY

Counsel for the Accused
Roll No. 67157
IBP No. 031321 – 02/08/2018 – Davao City
PTR No. 9734843 – 02/07/2018 – Davao City
(MCLE Governing Board Order No. 1, s. 2008)

NOTICE OF HEARING

THE CLERK OF COURT PROS. DANIEL M. FERNANDEZ

RTC Branch 11, Davao City Public Prosecutor

Greetings!

Please be informed that the instant Petition/Application is hereby being submitted

for the consideration and approval of the Honorable Court upon receipt hereof, and is set
for hearing on September 14, 2018 at 8:30 in the morning.

ATTY. ERICK JOHN S. CABUSLAY

EXPLANATION FOR SERVICE AND FILING BY REGISTERED MAIL

The service and filing of the foregoing Petition/Application was made by

registered mail due to distance, time, and personnel constraints. (Please disregard if
served or filed personally.)

ATTY. ERICK JOHN S. CABUSLAY

Copy furnished:

PROS. DANIEL M. FERNANDEZ

Davao City Prosecutors’ Office

PAROLE AND PROBATION OFFICE

Hall of Justice, Ecoland, Davao City

THE HONORABLE CLERK OF COURT

RTC Branch 11, Davao City

Page 3 of 3