Republic of the Philippines

REGIONAL TRIAL COURT

Fifth Judicial Region
Branch 51
Sorsogon City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

CRIM. CASE NO. 2014-8926

-versus- For: Violation of RA 9208, as
amended by RA 10364

MARILOU BURCE y BARAN

And JIMMY CLADO y CUELA,
Accused,
x--------------------------------------------x

MANIFESTATION WITH MOTION

ACCUSED, JIMMY CLADO y CUELA, by counsel and to the Honorable

Court, most respectfully states that:

1. Accused JIMMY CLADO y CUELA is presently detained in BJMP

Sorsogon City;
2. Upon careful perusal of the records, it appears that there is already an
affidavit of desistance executed by the private complainant, SHANINE
CASIA;
3. In the said affidavit, SHANINE unequivocally stated that “JIMMY
CLADO was not the person who recruited me for a job and was just also a
mere employee xxx I am no longer interested in pursuing the case against
accused JIMMY CLADO and the fact this decision I have come up with is
out of my voluntary act and free will xxx.” Attached hereto is the Affidavit
of Desistance of SHANINE as Exhibit “1;”
4. The undersigned counsel has verified and confirmed as to the voluntariness
of SHANINE when she executed that affidavit to the good handling
Prosecutor;
5. With this predicament and to expedite the proceedings of this case so as
not to waste the resources of the State, the accused JIMMY CLADO y
CUELA moves that his case be at least provisionally dismissed.

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed before
the Honorable Court that this manifestation with motion be noted and the case with
respect to JIMMY CLADO y CUELA be provisionally dismissed.
 Such other relief just and equitable under the premises is likewise prayed
for.

September 16, 2020. Sorsogon City.

PUBLIC ATTORNEY’S OFFICE

Counsel for the Accused
Bulwagan ng Katarungan
Sorsogon City

By:

ATTY. CHRISTIAN R. SANTONIA

Public Attorney II
Roll No. 70011
IBP O.R. No. 102562, 01-03-2020
MCLE Compliance No. VI – 0005934

NOTICE OF HEARING

The Clerk of Court

Regional Trial Court, Branch 51
Sorsogon City

Greetings!

Please be informed that the foregoing manifestation with motion will be formally
submitted before the Honorable Court upon receipt for its consideration and approval.

CHRISTIAN R. SANTONIA

Copy furnished:

PPO
Sorsogon City