REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SIXTH JUDICIAL REGION
BRANCH 36
ILOILO CITY

PEOPLE OF THE PHILIPPINES CRIM. CASE NOS. 14-73875

to 14-73876
- versus -

CEZAR TIBAJARES
Accused.
X - - - - -- - - - - - - - - - - - - - - - - - -X

VERY URGENT MOTION TO BRING

THE ACCUSED TO THE HOSPITAL
COMES NOW Accused through the undersigned counsel and unto to this Honorable
Court most respectfully requests:

1. That the Accused is a Senior Citizen and have been detained for two (2) years.
However, the Accused is presently sick and not in a good health condition as he spits blood
every time he coughs and heavily suffers chest pain. The Accused even presented himself for
initial check up before the Duty Physician of the BJMP Ungka, Jaro, Iloilo City, Dr. Jose Rene
T. Militante. Attached herewith are the prescribed medicines, laboratory examination request and
physician’s report all duly signed by Dr. Militante.

2. That there is an urgent need for the Accused to be brought to the hospital for proper
check up and timely medication.

WHEREFORE, premises considered, it is most respectfully prayed before the

Honorable Court that the Accused be allowed to be brought to the hospital for immediate check
up, undergo laboratory examination and proper medication.

Accused prays for such other relief just and equitable under the premises.

Iloilo City, Philippines, April 26, 2016.

RONALD Y. LAO
COUNSEL FOR THE ACCUSED
G/F ICCEMPC BLDG.
BONIFACIO DRIVE, ILOILO CITY
IBP LIFETIME NO. 891220/1-8-13/ I.C.
PTR NO. 5265477/ 1-4-16/ I.C.
 ROLL NO. 53133
MCLE COMP V-0005897/ 01-28-15
The Honorable Clerk of Court
RTC Branch 36
Iloilo Hall of Justice
Iloilo City

Greetings:

Please submit the foregoing Very Urgent Motion to Bring the Accused to the Hospital for
immediate consideration and approval of the Honorable Court.

RONALD Y. LAO

Copy furnished by personal delivery:

Pros. Ferdinand Thomas Magallanes

Public Prosecutor
City Prosecutors Office
Iloilo City

Received By: _____________. Date: _______________