Republic of the Philippines

12TH Judicial Region

4TH MUNICIPAL CIRCUIT TRIAL COURT OF
PIKIT-LIBUNGAN-ALEOSAN
Pikit, Cotabato

PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 2602

Plaintiff,

-versus- -for-

JUNEL ALAG, VIOLATION OF BP BLG 22

Accused.
x-------------------------------------x
PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 2603
Plaintiff,

-versus- -for-

JUNEL ALAG, VIOLATION OF BP BLG 22

Accused.
x-------------------------------------x
PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 2604
Plaintiff,

-versus- -for-

JUNEL ALAG, VIOLATION OF BP BLG 22

Accused.
x-------------------------------------x
PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 2605
Plaintiff,

-versus- -for-

JUNEL ALAG, VIOLATION OF BP BLG 22

Accused.
x-------------------------------------x
PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 2606
Plaintiff,

-versus- -for-

JUNEL ALAG, VIOLATION OF BP BLG 22

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

EX-PARTE MOTION TO DISMISS

Plaintiff, through Counsel, unto this Honorable Court, most respectfully states THAT:

The private complainant, Perfecto III F. Raagas, had already executed an “Affidavit of
Desistance”, attached as Annex “A” hereof, stating that is no longer interested in pursuing this case
against the accused and he will no longer appear in court whenever called to testify in these cases;

With this situation, there is no way by which the prosecution could possibly prove the guilt of
accused beyond reasonable doubt in this case.

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 It is therefore respectfully MOVED that the instant cases against accused,
JUNEL ALAG, be ordered DISMISSED for lack of intesrest to prosecute.

RESPECTFULLY SUBMITTED.

August 28, 2018, Kabacan, Cotabato

PROS. BONIFACIO P.
ESTREMOS
Plaintiff’s Counsel

NOTICE OF HEARING

The Clerk of Court

4TH MCTC of Pikit-Aleosan-Libungan
Pikit, Cotabato

Sir/Madam:

Please submit the above Motion for the consideration of the Honorable
Court at any date convenient with the court’s calendar.

August 28, 2018, Kabacan, Cotabato.

PROS. BONIFACIO P.
ESTREMOS
Plaintiff’s Counsel

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Republic of the Philippines)
Province of Cotabato ) s.s
Municipality of Kabacan )

AFFIDAVIT OF DESISTANCE

I, PERFECTO III F. RAAGAS, of legal age, married, Filipino and resident of

Kidapawan City, after having been duly sworn in accordance with law, do hereby
depose and say:

That I am the private complainant in Crim. Case Nos. 2602 to 2606 for
“Violation of B.P. Blg. 22” against Junel Alag, accused, now pending before the 4th
Municipal Circuit Trial Court of Pikit-Aleosan-Libungan;

That Junel Alag has already paid his obligations to me to my entire

satisfaction;

That I am no longer interested to further pursue all cases that I have filed
against him and will no longer testify against said accused in connection with
those cases;

That I am executing this affidavit freely, voluntarily and intelligently.

IN WITNESS WHEREOF, I have hereunto set my hand this 28 th day of

August, 2018 at Kabacan, Cotabato, Philippines.

PERFECTO III F. RAAGAS

Affiant

SUBSCRIBED AND SWORN to before me this 28th day of August, 2018 at

Kabacan, Cotabato, Philippines.

BONIFACIO P. ESTREMOS
Provincial Prosecutor