REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
CALOOCAN CITY BRANCH 1

PEOPLE OF THE PHILIPPINES CRIMINAL CASE NO. 1234

-VERSUS- FOR: MURDER

MR. A, ACCUSED

x---------------------------x

MOTION FOR BILL OF PARTICULARS

1. Assistant prosecutor filed this information on February 2, 2021 for murder against the
accused Mr. B
2. Under the Rules, a Motion for Bill of Particulars further specifies the charges or claims in
an information which an accused may avail of before arraignment to enable the accused
to prepare for trial.
3. Under the information filed by the Prosecution, they failed to provide the location and
the facts and circumstances surrounding the said felonious act that I allegedly did
against Mr. B. The information did not specify the location of the said attack.
4. The prosecution also failed to specify the fatal wound nor were they able to allege that
the attack was the direct, logical, and natural cause of the death of the victim.
5. In summary, the defense needs more information as to properly prepare for trial due to
lack of information surrounding the alleged murder of Mr. B.

PRAYER
Accused respectfully prays that:

1. The Court takes note of this motion

2. Order the prosecution to amend the information
Other equitable reliefs are likewise prayed for.

Caloocan City, Feb 8, 2022

Signed
Atty. X
Counsel for the accused
Roll No. 12345
IBP No. 12345
 PTR No. 12345
MCLE Compliance No. 12345
BBBB building Caloocan City

Notice of Hearing and

Copy furnished to:

THE BRANCH CLERK OF COURTT

NATIONAL CAPITAL JUDICAIL REGION
REGIONAL TRIAL COURT
CALOOCAN CITY BRANCH 1

ATTY. Y
ASSISTANT CITY PROSECUTOR
BBBB BUILDING CALOOCAN CITY

ATTY. Z
CITY PROSECUTOR
BBBB BUILDING CALOOCAN CITY

Greetings
Please be informed that this motion shall be submitted for the consideration of the Court on
February 8, 2022 at 9:00 am

Signed
Atty. X

EXPLANATION

A COPY OF THE MOTION WAS FILED AND SERVED VIA REGISTRED MAIL DUE TO LACK OF
MANPOWER

Signed
Atty. X
 REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
CALOOCAN CITY BRANCH 1

PEOPLE OF THE PHILIPPINES CRIMINAL CASE NO. 1234

-VERSUS- FOR: MURDER

MR. A, ACCUSED

x---------------------------x

MOTION TO AMEND INFORMATION

Assistant City Prosecutor respectfully states that:

1. Assistant Prosecutor filed this information on February 1, 2021 for the murder of Mr. A
against accused Mr. B.
2. Upon the Motion for Bill of Particulars submitted by Atty X, Mr. B’s counsel, the
prosecution files this motion to amend the information without leave of court provided
that the accused Mr. B have not entered his plea yet.
3. The Prosecution would like to specify that the gun used by the accused was retrieved in
his possession upon apprehension. The gun used to kill Mr. A by the accused Mr. B was
a black revolver gun. Attached in this motion as Exhibit B.
4. Further, the prosecution would like to add that the victim, Mr A was fatally wounded
and shot at the back and the bullet went through his heart which immediately caused
his death.
5. The amendments introduced by the prosecution are merely formal in nature and does
not require prior leave of court.
6. Under the Rules of Court, the information may be amended without leave of Court
before the accused enters his plea.

PRAYER
Assistant City Prosecutor respectfully prays that:

1. The Court takes note of this motion

2. Issue an order allowing the prosecution to amend the information.

Other equitable reliefs are likewise prayed for.

Caloocan City, (Date)

 Signed
Atty. Y
Assistant City Prosecutor
Roll No. 1234
IBP No. 1234
PTR No. 1234
MCLE Compliance No. 1234
AAAA building Caloocan City

Notice of Hearing and

Copy furnished to:

THE BRANCH CLERK OF COURTT

NATIONAL CAPITAL JUDICAIL REGION
REGIONAL TRIAL COURT
CALOOCAN CITY BRANCH 1

ATTY. X
Counsel for the accused
BBB Building

Greetings
Please be informed that this motion shall be submitted for the consideration of the Court on
February 14, 2022 at 9:00 am

Signed
Atty. Y

EXPLANATION

A COPY OF THE MOTION WAS FILED AND SERVED VIA REGISTRED MAIL DUE TO LACK OF
MANPOWER

Signed
Atty. Y
 AFFIDAVIT OF DESISTANCE

I, Mr. A, Filipino, of legal age, and a resident of Makati City, after having been sworn to in
accordance with law do hereby depose and state that:

1. I am the complainant in a criminal case of robbery against Mr. A pending before the
Regional Trial Court of Makati City Branch 1
2. During the pre-trial of the case as evidenced by the pre-trial order, Mr. B and I have
agreed on a settlement amounting to Forty Five Thousand Pesos (45,000) which he will
pay on June 9, 2022 in his residence in Makati City. Attached is the pre-trial order issued
as Exhibit A.
3. After being guided by my counsel and being informed of the repercussions of the
settlement, I have agreed to take the settlement offered by Mr. B.
4. I fully understand the consequences of executing an Affidavit of Desistance.
5. I am executing this affidavit to attest to the truth of the foregoing statements and
respectfully pray that the aforementioned case against Mr. B be withdrawn.

IN WITNESS WHEREOF, I have set my hands this June 14, 2022 in the City of Makati,
Philippines.

(signed)
Mr. A
Affiant

SUBSCRIBED AND SWORN to before me in the City of Makati with the affiant presenting
his passport with an ID Number of 12345 issued on January 1, 2011

Atty. X
NOTARY PUBLIC
Roll No. 12345
IBP No. 12345
PTR No. 12345
MCLE Compliance No. 12345
BBBB building Caloocan City
Doc. No. _1____;
Page No. _1____;
Book No. __1___;
Series of __2022___.
 REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION
REGIONAL TRIAL COURT
CALOOCAN CITY BRANCH 1

PEOPLE OF THE PHILIPPINES CRIMINAL CASE NO. 1234

-VERSUS- FOR: RA 9165

MR. A, ACCUSED

x---------------------------x

MOTION TO QUASH

Accused, through counsel, respectfully states that:

1. The assistant city prosecutor filed an information against the accused, Mr. A for
violation of RA 9165 which was field in Malabon City.
2. On January 2, 2022, accused was arraigned and pleaded not guilty to the offense being
charged.
3. Counsel for the accused filed a petition for Bail on Jan. 8, 2022. During this time, it was
found out that the crime was committed not in Malabon City but in Navotas City.
4. Under the Rules of Court particularly on Rule 117, a Motion to Quash may be filed at any
time before an accused enters his plea. However, when the grounds relied upon in the
motion are failure to charge an offense, lack of jurisdiction over the offense charged,
extinction of the offense of penalty, defendant will be placed in double jeopardy, a
motion to quash may be filed at any stage of the proceeding.
5. In this case, Mr. A was already arraigned and pleaded not guilty but it was found out
that during his Petition for Bail hearing that the crime actually took place in Navotas and
not in Malabon. In criminal procedure, venue is jurisdictional. Provided that the crime
committed is in Navotas and not Malabon, RTC Navotas has jurisdiction over the offense
charged against Mr. A.
6. As a result, the accused wishes to quash the motion on the ground that RTC Malabon
lacks jurisdiction over the offense charged.

PRAYER

Accused, through counsel, prays that:

1. The Court takes note of this motion
2. Issue an order regarding the quashal of this information for lack of jurisdiction over the
offenses charged.
Other equitable reliefs are likewise prayed for.

Malabon City, Jan. 14, 2022

Signed
Atty. X
Counsel for the accused
Roll No. 1234
IBP No. 1234
PTR No. 1234
MCLE Compliance No. 1234
BBBB building MALABON City

Notice of Hearing and

Copy furnished to:

THE BRANCH CLERK OF COURTT

NATIONAL CAPITAL JUDICAIL REGION
REGIONAL TRIAL COURT OF MALABON CITY BRANCH 1
BBB HALL OF JUSTICE MALABON CITY

ATTY. Y
ASSISTANT CITY PROSECUTOR
123 BUILDING MALABON CITY

ATTY. Z
CITY PROSECUTOR
123 BUILDING MALABON CITY

Greetings
Please be informed that this motion shall be submitted for the consideration of the Court on
January 5, 2022 at 9:00 am

Signed
Atty. X