REPUBLIC OF THE PHILIPPINES

First Judicial Region

REGIONAL TRIAL COURT
San Carlos City, Pangasinan
BRANCH 57

PEOPLE OF THE PHILIPPINES,

Plaintiff,
-versus- CRIMINAL CASE NO. SCC-9264
FOR: Qualified Theft
RONALD MATIAS y TADEO
Accused.
x--------------------------------------x

EX-PARTE MOTION
(to Allow Accused to Attend Interment/Burial)

IN
THE HIGHEST INTEREST OF JUSTICE, ACCUSED, through
the undersigned counsel, humbly comes into this Honorable Court, most
respectfully avers and states that:

1. ACCUSED in the above entitled case is currently detained at

the BJMP, San Carlos City Pangasinan;

2. ACCUSED, is the brother of JOHNNY TADEO MATIAS;

3. JOHNNY TADEO MATIAS died last February 12, 2023 due

to a cause as indicated in the attached Death Certificate
marked as Annex A;

4. JOHNNY TADEO MATIAS interment is on February 18,

2023 (8:00am). Necrological announcement tarpaulin and
the service contract with Funeraria Ventenilla are herein
attached and marked as Annex B and B-1;

5. JOHNNY TADEO MATIAS will be buried at Roman

Catholic Cemetery, Dagupan City1.;

6. Accordingly, herein ACCUSED begs great indulgence and

compassion to the Honorable Court that he be allowed to
attend interment of his brother; and

1
As reflected in Entry No. 25 of the attached Death Certificate

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 7. ACCUSED has no intention to escape, but only bolstered by
their desire to pay due respect to his beloved brother.

RELIEF

WHEREFORE, in view of the foregoing, herein ACCUSED, through

the undersigned counsel most respectfully moves unto the Honorable Court
that the foregoing motion be GRANTED to the effect that that he be
allowed to attend interment of JOHNNY TADEO MATIAS on February 18,
2023 (8:00am) to be escorted by the official guards of the BJMP, San
Carlos City Pangasinan. Other reliefs which are just and equitable under
the circumstances are likewise sought for. Done this February 15, 2023, in
the City of San Carlos, Pangasinan.

PUBLIC ATTORNEY’S OFFICE

San Carlos City District Office
San Carlos City, Pangasinan

By:

GLAMOUR JOHN L. TULAGAN

Public Attorney II
Roll of Attorney's No. 71129
I.B.P. O.R. Nos. 292490 & 292491/January 23, 2023
MCLE Compliance No. VII – 0024587 valid until April 14, 2025

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 NOTICE
ATTY. PURISSA M. REYES
Branch Clerk of Court
RTC Branch 57
San Carlos City, Pangasinan

PLEASE submit the foregoing motion to the Honorable Court for its
kind consideration and approval.

THANK you.
Counsel

Copy Furnished:

PROS. MITCHEL A. GO
Deputy City Prosecutor
OFFICE OF THE CITY PROSECUTOR
Ground Floor, Hall of Justice
Brgy. Pagal, San Carlos City
Pangasinan 2420 …………………. by personal service

ATTY. GERALDINE UBANA BANIQUED

Counsel for Private Complainant
BANIQUED LAW OFFICE
Pogo, Mangaldan, Pangasinan …………………. by registered mail

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