Professional Documents
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Criminal Case No.00-12773-13 &12774-13
FOR : QUALIFIED THEFT
EMELITA C. MAGRACIA,
HERMENLYN D. MONTOYA,
ELSA BULAHAN VALLAR,
DELMA GATOC,
JEFFERSON FERRER TIAUZON,
NOLLY BOY HALIM,
ANITA CASTILLO,
LUZ SIPAGAN,
ANNIE ARIOLA &
TESS LIMPIN,
Accused
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only be burdened by baseless accusation not worthy of a fuller
examination.
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6. That the taking was done under any of the circumstances
enumerated in Art. 310 RPC with grave abuse of confidence (
Mafudo v Pp G.R. No. 179061 July 13, 2009)
7. All told, the accused herein respectfully submits that since the
facts accrued by the complainants do not at all show criminal
liability and the resolution of the City prosecutor taking its
whole context does not admit that the crime of qualified theft
was committed. If is therefore but imperative that the
information be quash not only for lack of probable cause but
clearly the facts as shown does not constitute an offense.
Respectfully Submitted,
Copy furnished;
Apolinar S. Caparal
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Vempauljor Corp, KM 29, Aguinaldo Hi-way,
Salitran 2, Dasmarinas City, Cavite