Republic of the Philippines

Regional Trial Court

10th Judicial Region
Branch 20
Bayugan City

People of the Philippines, Search Warrant No. 10201

Plaintiff,

-versus-

Alias Kingkong Vecilla

Alias Berto Capito
Alias Jeraya Mae
Accused.
x-----------------------------x

APPLICATION FOR SEARCH WARRANT

COMES NOW, the undersigned AGENT BATO IBARRA, Filipino, of legal age, Married and
a Drug Enforcement Officer of the Philippine Drug Enforcement Agency, currently assigned at Philippine
Drug Enforcement Agency Regional Office XIII (PDEA RO XIII, for brevity) with office address at
Provincial Hospital Compound, Libertad, Butuan City, Agusan del Norte, Philippines and unto this
Honorable Court, under oath, most respectfully prays and state that;

1. I have been informed that a certain alias Kingkong Vecilla (male, married, more or less 60 years
of age, medium build and more or less 5'7" height), alias Berto Capito (female, married, more or
less 60 years of age, large build and more or less 5'7" height) and alias Jeraya Mae (female,
single, more or less 25 years old and more or less 5'2" height) of P Malbas Street, Brgy 9,
Cabadbaran City particularly described on a sketch herein attached and made an integral part
hereof, are in possession of, and has in their control, without authority of law, undetermined
quantity of Methamphetamine Hydrochloride and dried Marijuana Leaves, a dangerous drugs,
which they are keeping and concealing in their house located at the above-mentioned address;

2. Based on the information and attestation of the witness, Agent Luca Pacioli, certification and
documents, are hereto attached and likewise made integral part hereof, there is reasonable ground
to believe that said respondents are in control, custody and possession of the aforementioned
undetermined quantity of dangerous drugs without authority of law, including fruits thereof, such
as, but not limited to cash, bank accounts, receipts, books of accounts, and other means of
committing the offense;

3. It is of great and urgent necessity that a search warrant should be issued to enable any agent of
the law to immediately confiscate and seize at ANY TIME OF THE DAY OR NIGHT, and
 bring the seized and confiscated items to this Honorable Court and to preclude the respondents
from disposing of and/or delivering, or distributing said dangerous drugs to the public;

4. Considering the vulnerability of the drugs, wherein it could be disposed of in a short period of
time or put to waste in such a manner that their evidentiary value will be significantly affected, a
WARRANT TO SEARCH AT ANYTIME OF THE DAY OR NIGHT is indispensable to the
confiscation and seizure of said dangerous drugs before it is brought out of the premises and into
the public;

5. By way of justification, we have gathered and verified information that the subjects are known to
have friends and/or clients who might have access directly or indirectly in the Regional Trial
Court of Cabadbaran City, Agusan del Norte, and in the Regional Trial Courts of Butuan City the
same are considered as compelling reasons for the undersigned to apply instead before the
Honorable Court.

WHEREFORE, the undersigned respectfully prays that the Honorable Court issue a Search
Warrant commanding any Law Enforcement Officer to conduct search of the abovedescribed premises
AT ANY TIME OF THE DAY OR NIGHT and of the person of the respondents involved and to seize
the persons involved and the undetermined quantity of dangerous drugs above-mentioned including the
proceeds or fruits in connection with the violation of RA No. 9165 and those used or intended to be used
by the respondents as a means of committing the offense, to be brought before the Honorable Court to be
dealt with as the law directs.

IN WITNESS WHEREOF, I have hereunto set my hand this 4th day of December 2021 at
Bayugan City, Philippines.

AGENT CARLO CABIDO

Applicant

SUBSCRIBED AND SWORN to before me this 4th day of December, 20201 at Bayugan City,
Philippines.

Doc. No. __2___;

Page No. __2__;
Book No. __2_;
Series of 2021.