REPUBLIC OF THE PHILIPPINES

IN THE MUNICIPAL TRIAL COURT OF GEN. TINIO

PROVINCE OF NUEVA ECIJA

PEOPLE OF THE PHILIPPINES,

Complainant,

-versus- CRIM. CASE NO. 09-2003

SHERWIN PAJARILLAGA,
Accused.
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MOTION TO WITHDRAW AS COUNSEL

COMES NOW, the undersigned counsel and to this Honorable Court

respectfully alleges:

1. That during the arraignment and pre-trial in the above-entitled case,

accused was represented by counsel de officio, Atty. Nathaniel
Ramos;

2. That on several times that the above-entitled case was scheduled for
hearing, undersigned counsel failed to appear due to conflict of
schedules and his appearances before the Regional Trial Courts in
Gapan City;

3. That because of this non-appearance of the undersigned which was

already explained, the private complainant in the above-entitled case
filed a complaint against the undersigned with the Chief Public
Attorney of the PAO and in her undated, unsigned reply to the
comment of the undersigned to her complaint, the latter even
suggested and I quote: “sabi ng akusado hindi daw po kasi available
si Atty. Romano. Ganoon po pala yon e bakit hindi bitawan. Lagi na
lang po bang reset ng reset ang hearing?”

4. That in view of the filing of a letter-complaint by the private

complainant against the undersigned and in order to satisfy the
suggestion of the private complainant in her reply and in fairness to
the accused who is entitled to be represented by a lawyer of his choice
who can dutifully attend to all the hearings in the above-entitled case,
it is respectfully prayed that the undersigned be allowed to withdraw
as counsel for the accused.

PREMISES CONSIDERED and in the interest of justice, it is

respectfully prayed that undersigned be allowed to withdraw his appearance
as counsel for the accused.
 Such other reliefs and remedies just and equitable in the premises are
likewise prayed for.

Gapan City, February 20, 2006

PUBLIC ATTORNEY’S OFFICE

Gapan City District Office
2nd Floor, 4J Bldg., Bucana, Gapan City
Counsel for the Accused

By:

IRENEO A. ROMANO
District Public Attorney
IBP OR NO. 647873 - 1/05/06
ROLL OF ATTY. NO. 27182
PTR No. 0143552 - Feb. 10, 2006
The Clerk of Court
MTC-Gen. Tinio
Gen. tinio, Nueva Ecija

Greetings:

Immediatley upon receipt hereof, please submit the foregoing Motion

to the Honorable Court for its kind consideration and approval.

IRENEO A. ROMANO

Copy furnished:

Atty. Feliciano Buenaventura

Private Prosecutor
Magsaysay Sur, Cabanatuan City

CERTIFICATION

Due to distance and lack of personnel, a copy of this pleading was

served to private prosecutor thru registered mail with return card.

IRENEO A. ROMANO