REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
Branch 48
Urdaneta City, Pangasinan

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus-
CRIM. CASE NOS. U-22806-
07
FOR: ILLEGAL SALE /
POSSESSION OF
DANGEROUS DRUGS

MARK ANTHONY BALBIN,

Accused.
x----------------------------------------x

MANIFESTATION AND MOTION

The accused, assisted by the Public Attorney’s Office (PAO),
through the undersigned counsel, unto this Honorable Court most
respectfully states that:

1. On February 3, 2021, the accused, through the

undersigned
Public Attorney, filed his Urgent Motion to Release on Recognizance 1
wherein the former respectfully prayed that he be released upon the
recognizance of the barangay officials of Barangay Nancayasan,
Urdaneta City, Pangasinan, namely Mark Anthony G. Reyyes, and
Sonny M. Valdez. In the same Urgent Motion, the accused attached
his Certificate of Detention and the Affidavit of Recognizance
executed by the said barangay officials;

2. Unfortunately, the said Urgent Motion was denied by the

Honorable Court in its Order dated February 22, 2021 which was
received by the undersigned counsel on March 17, 2021. The
Honorable Court denied the said Urgent Motion considering that the
Barangay Officials who executed the said Affidavit of Recognizance
are not from Barangay Imbalbalatong, Urdaneta City, Pangasinan;

1
February 3, 2021
 3. Thus, attached hereto as Annex “1” is the Joint Affidavit of
Recognizance of the barangay officials of Barangay Imbalbalatong,
Pozorrubio, Pangasinan namely Jaime Aspiras Obra, and Allan
Dela Cruz Pajarillo;

4. To reiterate, the accused was charged charged for the

offenses of Illegal Sale of Dangerous Drugs (U-22806) and Illegal
Possession of Dangerous Drugs (U-22807);

5. By reason of his plea of guilty in both cases to the lesser

offense of violation of Section 12, Article II, of R.A. No. 9165 (Illegal
Possession of Drug Paraphernalia), he was sentenced to suffer the
penalty of imprisonment of SIX (6) MONTHS AND ONE (1) DAY as
minimum to FOUR (4) YEARS as maximum and to pay a fine of Php
40,000.00 for each case. The accused has fully served his sentence
as shown in the Certificate of Detention hereto attached as Annex
“2”;

6. Therefore, pending the conduct of the required Drug

Dependency Evaluation (DDE), the accused respectfully prays that
he be allowed to be released on recognizance and that the barangay
officials of Barangay Barangay Imbalbalatong, Pozorrubio,
Pangasinan namely Jaime Aspiras Obra, and Allan Dela Cruz
Pajarillo, be further allowed to personally assist the accused in the
conduct of his Drug Dependency Examination (DDE) at the DOH
Drug Treatment and Rehabilitation Center, Dagupan City.

WHEREFORE, in view of the foregoing, Accused-movant most

respectfully prays that he be released on recognizance pending the
conduct of his Drug Dependency Examination (DDE).

Other reliefs which are just and equitable in the premises are
also prayed.

Urdaneta City, Pangasinan. March 17, 2021.

PUBLIC ATTORNEY’S OFFICE

Urdaneta City District Office
Hall of Justice, Urdaneta City
Pangasinan

BY: ATTY. JIM JOEL N. SANTOS

Public Attorney II
IBP Lifetime No. 014930
Pampanga Chapter
Roll No. 65940
MCLE Compliance No. VI – 0012051
 NOTICE

The Branch Clerk of Court

RTC, Branch 48
Urdaneta City, Pangasinan

Greetings!

Please submit the foregoing Motion for the consideration of the

Honorable Court immediately upon receipt hereof.

Thank you!

Counsel

COPY FURNISHED: By personal service

PROS. NOEL T. NERIZON

Office of the City Prosecutor
Urdaneta City, Pangasinan