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    Plea Bargaining Santiago

    Uploaded by

    Kenneth Mercado
    The document is an omnibus motion filed in a criminal case in the Regional Trial Court of Malolos City, Bulacan. It requests that (1) the accused be allowed to withdraw their previous plea of not guilty to violating Section 5 of R.A. 9165 and (2) be permitted to enter a new plea of guilty to the lesser offense of violating Section 12 of R.A. 9165 instead. The motion is filed on behalf of the accused by the Public Attorney's Office.

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    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd

    Plea Bargaining Santiago

    Uploaded by

    Kenneth Mercado
    284 views2 pages
    The document is an omnibus motion filed in a criminal case in the Regional Trial Court of Malolos City, Bulacan. It requests that (1) the accused be allowed to withdraw their previous plea of not guilty to violating Section 5 of R.A. 9165 and (2) be permitted to enter a new plea of guilty to the lesser offense of violating Section 12 of R.A. 9165 instead. The motion is filed on behalf of the accused by the Public Attorney's Office.

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    Plea

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    The document is an omnibus motion filed in a criminal case in the Regional Trial Court of Malolos City, Bulacan. It requests that (1) the accused be allowed to withdraw their previous plea of not guilty to violating Section 5 of R.A. 9165 and (2) be permitted to enter a new plea of guilty to the lesser offense of violating Section 12 of R.A. 9165 instead. The motion is filed on behalf of the accused by the Public Attorney's Office.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    284 views2 pages

    Plea Bargaining Santiago

    Uploaded by

    Kenneth Mercado
    The document is an omnibus motion filed in a criminal case in the Regional Trial Court of Malolos City, Bulacan. It requests that (1) the accused be allowed to withdraw their previous plea of not guilty to violating Section 5 of R.A. 9165 and (2) be permitted to enter a new plea of guilty to the lesser offense of violating Section 12 of R.A. 9165 instead. The motion is filed on behalf of the accused by the Public Attorney's Office.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    of 2

    Republic of the Philippines

    REGIONAL TRIAL COURT


    Third Judicial Region
    Malolos, Bulacan
    Branch 80

    PEOPLE OF THE PHILIPPINES,

    -versus- Crim. Case No. 4092-M-


    2014
    For: Viol. of Section 5 and 11,
    Art. II of R.A. 9165
    RODOLFO SANTIAGO, JR y
    RUBIO,
    ORLY DELA PAZ y VALMONTE.
    Accused.
    x------------------------x

    OMNIBUS MOTION TO ALLOW ACCUSED TO


    PLEAD GUILTY TO LESSER OFFENSE

    ACCUSED, assisted by the Public Attorney’s Office,


    through the undersigned counsel, respectfully states that:

    1. Accused herein stands charged for Violation of Section


    5, Article II of R.A. No. 9165 involving a plastic sachet
    of suspected shabu weighing 0.4726 gram;

    2. When the accused were arraigned, they pleaded “not


    guilty” to the aforementioned charge;

    3. In view of the declaration of Section 23 of R.A. No. 9165


    as unconstitutional in the case of Estipona, Jr. v. Lobrigo, et
    al., (G.R. No. 226679, 15 August 2017), the accused
    respectfully moves that they be allowed to withdraw their
    previous plea to the aforesaid charges and to plead anew to
    the lesser offense of Violation of Section 12 of R.A. No. 9165, in
    accordance with A.M. No. 18-03-16-SC (Adoption of the Plea
    Bargaining Framework in Drug Cases).

    PRAYER

    WHEREFORE, premises considered, it is most


    respectfully prayed of this Honorable Court that an Order be
    issued: (A) allowing the accused to withdraw their previous
    plea; and (B) allowing them to enter a new plea to the lesser
    offense of Violation of Section 12 of R.A. No. 9165;
    Other reliefs as may be deemed just and equitable under
    the premises are likewise prayed for.
    Malolos City, Bulacan. March 6, 2019

    Respectfully submitted.

    Department of Justice
    PUBLIC ATTORNEY’S OFFICE
    2nd Floor, Hall of Justice Building
    Provincial Capitol Compound
    City of Malolos, Province of Bulacan

    By:

    KENNETH N. MERCADO
    Public Attorney II
    Roll No. 64388 (Bulacan Chapter)
    IBP Lifetime Roll No. 014539 (Jan, 8, 2016)
    MCLE Compliance No, VI- 0010162 (7-6-18)

    NOTICE

    Atty. MARIA CARLA L. CAMUA- DELA PAZ


    Branch Clerk of Court
    Regional Trial Court, Branch 80
    Malolos City, Bulacan

    Greetings:

    Kindly submit the foregoing motion for the


    consideration and approval of the Honorable Court and
    kindly set this case for hearing on March 7, 2019, or on such
    other dates deemed convenient to the Honorable Court.

    KENNETH N.
    MERCADO

    Copy furnished: by personal service

    Pros. Marcelo SP. Mendoza.


    Public Prosecutor
    Office of the Provincial Prosecutor
    Malolos City

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