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Republic of the Philippines

National Capital Judicial Region


REGIONAL TRIAL COURT
Branch XX, Manila

PEOPLE OF THE PHILIPPINES,


Plaintiff,

- versus - Crim. Case No. 14-302742


For: xxxx

GENO SORSOGON y REGALA,


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

APPLICATION FOR PROBATION

Comes now the ACCUSED, through the undersigned


counsel and unto this Honorable Court, most respectfully
applies for probation under the provisions of Presidential
Decree No. 968 as amended and states that:

1. On May 25, 2015, Accused was convicted of the crime


charged herein and was sentenced to suffer four (4) months
imprisonment;

2. He failed to attend the promulgation of judgment of this


case because he did not receive any Order coming from the
Honorable Court as to its date;

3. In fact, Accused also did not received any


process/communication of this Honorable Court after he was
arraigned. In fact, his non-receipt of any process of the
Honorable Court is the sole reason why he failed to adduce his
side of the story in this case;

4. Accused never intended his non-participation in this case


but was waiting all along about its outcome. He was utterly
surprised to learn last September 7, 2018 that a judgment was
already rendered in this case;

5. The crime for which the accused was convicted is not an


offense against national security or public order;
6. Accused has not been previously convicted by final
judgment of any offense;

7. Accused has not been once placed on probation under


the provisions of Presidential Decree No. 968, otherwise
known as the Probation Law of 1976, as amended;

8. Accused has all the qualifications and none of the


disqualifications to avail of the benefits of the Probation Law;

9. Accused has not started to serve his sentence and has


not filed any Appeal from the Decision of the Honorable Court;

10. He is gainfully employed and is substantially


contributing to his family such that detention will deprive him
and them, of source of income; and,

11. Accused’s correction, rehabilitation and reformation


will be best serve through probation because of its
individualized treatment approach;

WHEREFORE, premises considered, it is most


respectfully prayed of this Honorable Court that the
Application for Probation be referred to the Parole and
Probation Officer of Manila for the requisite post-sentence
investigation and thereafter, the application for probation be
approved.

Other reliefs just and equitable in the premises are


likewise prayed for.

Quezon City for the City of Manila, September 17, 2018.

XXXX

NOTICE OF HEARING

THE BRANCH CLERK OF COURT


RTC-Branch 5
Manila

Greetings!
Please submit the foregoing motion to the Honorable
Court on September 21, 2018 at 8:30 in the morning for its
favorable consideration and approval.

xxxx

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