Republic of the Philippines

DEPARTMENT OF JUSTICE
NATIONAL PROSECUTION SERVICE
Office of the Secretary
Padre Faura St., Ermita, Manila

PEOPLE OF THE PHILIPPINES,

Complainant-Appellant ,
Case No. _____________
For: Qualified Theft under Article 310
- versus - of the Revised Penal Code

LIZARDO MONDRAGON,
Defendant.
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PETITION FOR REVIEW

COMES NOW, the undersigned petitioner, unto this Honorable Office
respectfully avers:
1. That on 4 January 2023, the undersigned Chief of Police of Quezon
City Police District, upon complaint of the private offended party filed a
case against LIZARDO MONDRAGON of 414 Tax St. Brgy. Holy
Spirit, Quezon City for QUALIFIED THEFT docketed under IS No. 88-
7777 before the Office of the City Prosecutor;
2. That for the information of the Honorable Secretary this case
started, as follows:
a. That on the morning of November 6 December 2022, I was
riding my Vespa motorcycle going to our nearest 7-11
Convenience Story, LIZARDO MONDRAGON took my Vespa
Motorcycle, when I was inside the store premises;
c. That according to the eyewitnesses, LIZARDO
MONDRAGON is a habitual offender;
d. That we immediately called the Village Security and the nearest
Police station to report the incident;
e. That upon filing of the information in the precinct, we
submitted the testimony of the eyewitnesses and the CCTV
Camera of the convenience store;

3. That on 3 December 2022, the undersigned received the Resolution of

the Honorable Prosecutor copy of which is attached as Annex "A
disposing the case as follows:
 WHEREFORE, IN VIEW OF THE FOREGOING, it is
most recommended that the complaint filed be dismissed for the
lack of probable cause.
4. That the Honorable Prosecutor believes that undersigned erred in
considering the basis of the complaint filed.
5. That with due respect, the undersigned believed that the Honorable
Prosecutor committed error on the following:
a. That the complainant had substantial evidence, that is clear and
convincing in proving the guilt the accused.
6. Attached as integral part of this petition are the following:
a. Proof of service of this Petition to the Honorable Prosecutor
(Annex “B")
b. Proof of service of this Petition to the Appellee
c. Other Records of the Case

WHEREFORE, the undersigned respectfully prays for the setting aside of the
appealed resolution of Assistant Prosecutor ARIES A. VOLTURI dated 03
December 2022 and that the honorable prosecutor be directed to file
information so demanded by the plaintiff-appellant.
Complainant further prays for other just and equitable reliefs under the premises.
Quezon City. 5 March 2023.