Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

Branch 1
General Santos City

People of the Philippines, Criminal Case No.

Plaintiff, 65384-1

- versus - - for -
RECKLESS IMPRUDENCE
WES, RESULTING TO LESS
Accused. SERIOUS PHYSICAL INJURIES
x------------------------------x

MOTION TO RECALL OR LIFT WARRANT OF ARREST

Accused, through counsel, and to his Honorable Court respectfully

states that:
1. This motion is filed in consonance with the accused’s constitutional
presumption of innocence and will not prejudice anyone;
2. Despite notice, herein accused was not able to attend the
scheduled hearing of this case because he was under quarantine at the
GSC Isolation Facility after being in close contact with a COVID-19 positive
person (certification is hereto attached as Annex “A”) ; and
3. This motion does not intend to delay any proceeding of this
Honorable Court.
WHEREFORE, premises considered, it is respectfully prayed unto
this Honorable Court to recall its Order and lift the warrant of arrest issued
against the accused.
Other just and equitable remedies are likewise prayed for.

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 General Santos City, Philippines, May 16, 2022.
Respectfully submitted.

ATTY. JOHN FROY B. TABINGO

COUNSEL FOR THE ACCUSED
PNC No. 16-89 until December 31, 2022
Roll of Attorney No. 832741
PTR No. 7912748/01-04-2022/GSC
IBP Lifetime No. 14323
MCLE Compliance No. VI-323423
Valid until November 10, 2022

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

MTCC, Branch 1
General Santos City

PROSECUTOR LINCOLN VINTOLERO

Office of the City Prosecutor, General Santos City

Greetings!
Please take notice that the undersigned counsel will submit the
foregoing Motion to Honorable Court on May 19, 2022 at 2:30 in the
afternoon for its favorable consideration and approval.

ATTY. JOHN FROY B. TABINGO

COUNSEL OF THE ACCUSED

Copy furnished:

Prosecutor Lincoln Vintolero

OCP – General Santos City

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