Republic of the Philippines

REGIONAL TRIAL COURT

First Judicial Region
Branch 17
Batac City, Ilocos Norte

People of the Philippines,

Plaintiff,
-versus- Crim Case No. 5745-17

EDMUND TADENA SR. ET. AL.

Accused
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MANIFESTATION WITH OMNIBUS MOTION

COMES NOW, the accused, through the

undersigned counsel, respectfully states:

1. That the accused was given ten days to file his

demurrer to evidence with leave of court;

2. That the undersigned counsel was not able to file on

time the demurrer to evidence because his mother was
in and out of the hospital and eventually died on
February 5, 2023. She was just buried on August 16,
2023; 

3. That undersigned counsel had just finished studying

the records of the case, after a careful study of the
evidence presented about the crime charged, the
undersigned counsel strongly believes that the
prosecution failed to prove the guilt of both accuse
beyond reasonable doubt.  The MEMORANDUM filed by
accused Tadena pointed out all the damning
inconsistencies and different versions of the
prosecution’s witnesses. The said Memorandum applies
as well to the other accused because the allegations
against them were the same; 

5. That so as not to burden the Honorable Court of

setting the dates for the presentation of evidence for the
accused  and not to  prolong the unjust  deprivation of
the liberties of both accused for being wrongfully
charged for the crime they did not commit,  the accused
is adopting the evidence presented by accused Tadena
to be his evidence considering that both accused
together with three others who are still at large were
charged allegedly in conspiracy with one another to
perpetrate the crime charged;

6. That upon careful and diligent explanations to the

accused of the evidence presented during the trial of
accused Tadena, the effects and results of adopting the
same, the accused voluntarily and accordingly had given
his consent to the undersigned not to testify to the
Honorable Court to prove his innocence;

WHEREFORE, premises considered, it is most

respectfully prayed of the Honorable Court to:

       1. Allow the adoption of the evidence presented by

accused Tadena to be or form part of the evidence of his
co-accused;

        2. Allow the defense to rest their case sans

testimony of the other accused

3. Allow the adoption of the MEMORANDUM filed

by the accused Tadena to be the MEMORANDUM of the
accused.

Following the allowance of the foregoing, it is most

respectfully prayed that the case be submitted for
Decision.

Other relief and remedies which are deemed

necessary and desirable under the premises are likewise
prayed for.

Vigan City, Ilocos Sur for Batac City, Ilocos Norte,

August 17, 2023.

ATTY. JOEL R. MARQUEZ

Counsel for the Accused
JRH Building II, Alcantara St. Cor. Del Pilar Extn.
Brgy. VIII, Vigan City, Ilocos Sur
ROLL NO. 52377/May 11, 2006
PTR NO. 57694156 / January 3, 2022
IBP NO. 143975/ February 3, 2021
MCLE Compliance No. 0018737 / April 14, 2022
Tel. No. 09156329503
EMAIL NO. joelegalcharm@outlook.com
Copy furnished:

Thru Electronic mail

Atty. Macario Arquillo
arquillomac20@gmail.com

Provincial Prosecutor Batac Ilocos Norte

oppilocosnorte@doj.gov.ph
rgcalupig@yahoo.com