Republic of the Philippines

METROPOLITAN TRIAL COURT

National Capital Judicial Region

PEOPLE OF THE PHILIPPINES,

- versus -
Criminal Case No.
______,
Accused.

MOTION TO RESET HEARING TO AN EARLIER DATE

COMES NOW, ACCUSED, through the undersigned counsel, unto

this Honorable Court, most respectfully states that:

1. On _____, this case has been set for Arraignment and Pre-trial
Conference, whereby the Accused entered a plea of “Not Guilty” on
both charges;

2. After the conclusion of the Arraignment and Pre-trial, the initial

trial for this case has been set on __ at ___ o’clock in the morning;

3. However, upon conferring with the Accused, he intimated to

the undersigned counsel his desire to withdraw his earlier plea of not
guilty, and to plead guilty to the above-captioned case for ___ and to
enter into plea bargaining with respect to the other charge for
G_____;

4. Records reveal that the Accused is a detention prisoner who

has been in custody since ___;

5. In view of the foregoing, the Accused, through the

undersigned, hereby respectfully requests of the Honorable Court to
allow the resetting of the hearing on the instant cases to an earlier
date on___at ___ o’clock in the ____, subject to the availability and
convenience of the Honorable Court’s calendar;

6. This Motion is made in good faith and not intended to delay

the proceedings of the instant case.

PRAYER

WHEREFORE, PREMISES CONSIDERED, it is respectfully prayed

of this Honorable Court that the hearing set on ___ be reset to ___,
subject to the availability and convenience of the Honorable Court’s
1
calendar.

NOTICE

Branch Clerk of Court

Metropolitan Trial Court

Greetings:

Kindly submit the foregoing Motion to the kind consideration of the

Honorable Court immediately upon receipt hereof.

Thank you.