LFW3

TABLE OF CONTENTS
1. Criminal information for Murder

2. Criminal information for Homicide
3. Criminal information for Libel
4. Criminal information for BP Blg 22
5. Motion to quash criminal complaint
6. Demurrer to Evidence
7. Petition for Bail
8. Motion to Reduce Bond/Bail
9. Motion to Suspend Proceedings
10. Ex Parte Motion to set the case for pre-trial conference
REPUBLIC OF THE PHILIPPINES
National Capital Judicial Region
REGIONAL TRIAL COURT
City of Manila
Branch 44
PEOPLE OF THE PHILIPPINES,

Plaintiff,
-versus- CRIMINAL CASE NO. 24242

For: Murder
EARL ESTACIO,
Defendant.
x-----------------------------------------------------x
INFORMATION
The undersigned Assistant City Prosecutor, upon sworn

complaint originally filed by the offended party, accuses EARL
ESTACIO of the crime of MURDER, committed as follows:
That on or about January 15, 2017 in the city of Balanga,

province of Bataan, Philippines, within the jurisdiction of this court,
the said accused, did then and there, with malice aforestated and
with deliberate intent to take the life of ANGELA SABAUPAN,
wilfully, unlawfully, feloniously, suddenly and treacherously attack
the latter with a knife, fist wounding him in the chest, and
afterwards, when enfeebled and unable to defend himself, again in
the stomach, both wounds being necessarily mortal, thereby
causing the direct and immediate death of said ANGELA
SABAUPAN.
Contrary to law.
Bataan, Philippines. April 2, 2017
(SGD) Earl Estacio

Assistant City Prosecutor
Witnesses: 1. Ricky Flores 12 Del Monte Quezon City

2. Beth Tamayo 222 Mayon Quezon City
Bail Recommended: P10,000

CERTIFICATION
I hereby certify that the preliminary investigation in this case

has been conducted; I have examined the complaint and his
witnesses and on the basis of their sworn statements and other
evidence submitted before me there is reasonable ground to
believe that the offense charged has been committed; the accused
was informed of the complaint and was given an opportunity to
submit controverting evidence and that the filing of this
information was with the authority of the City Prosecutor.
Earl Estacio
SUBSCRIBED AND SWORN to before me this 3rd day of MARCH

2017. Balanga, Bataan.
Randy David
Administering officer
Republic of the Philipines
Branch 22, Quezon City

Plaintiff,
-versus- Criminal Case: 12345

For: Libel
Dr. Alicia Santos and Fr. Rolly Dela Vega,

Accused.
x - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -x
INFORMATION
The undersigned prosecutor accuses Dr. Alicia Santos and Fr.

Rolly Dela Vega of the crime of libel, committed as follows:
On or about 22 December 2015 in the City of Quezon, the

accused, being then the editors in newspapers titled Pilipinas
Balita, published in general circulation in the Philippines,
voluntarily, feloniously and with the intention of attacking the
honesty, virtue and reputation of ABA Educational System Inc. and
for the purpose of exposing her to public hatred and ridicule, wrote
in Issue No. 123 of said newspaper, an injurious and defamatory
article which is in words as follows:
Ang kapal naman ng mukha ng eskwelahang ito, itong si

ABA Educational System, para magpatuloy sa pagtanggap ng mga
estudyante at pagtanggap ng enrollees kahit na walang permit
galling sa CHED. Hindi dapat pinapahintulutan itong eskwelahang
ito na ipagpatuloy ang kanilang illegal na aktibidad sapagkat
sinisira lamang nila ang buhay ng mga batang ito at binibigyan nila
ng false hope ang kinabukasan nila.
The article in question had for its object to insinuate and made
it understood, and interpreted by the public who read it, that the
school referred to is no other that ABA Educational System Inc, and
in this manner transmitting maliciously to the public the impression
that the school has no permit to operate as an educational
institution, with the purpose of destroying their reputation before
the bar of public opinion.
Contrary to Law.
Quezon City, 22 February 2016.
(SGD) Laurence Taguinod


CERTIFICATION

Laurence Taguinod
Subscribed and sworn to before me this 27 February 2016 in

Quezon City.
Ricardo Puno
City of Manila
Branch 44

Plaintiff,

For: Homicide
EARL ESTACIO,
Defendant.
x-----------------------------------------------------x
INFORMATION

complaint originally filed by the offended party, accuses EARL
ESTACIO of the crime of MURDER, committed as follows:
That on or about January 15, 2017 in the city of Balanga,

province of Bataan, Philippines, within the jurisdiction of this court,
the said accused, did then and there, with malice aforestated and
with deliberate intent to take the life of NICU DELA MERCED,
wilfully, unlawfully, feloniously, suddenly and treacherously attack
the latter with a knife, fist wounding him in the chest, and
afterwards, when enfeebled and unable to defend himself, again in
the stomach, both wounds being necessarily mortal, thereby
causing the direct and immediate death of said NICU DELA
MERCED.
Contrary to law.
Bataan, April 2, 2017

(SGD) Earl Estacio


CERTIFICATION

Earl Estacio

2017 Balanga, Bataan.
Randy David
City of Manila
Branch 44
YRIZ TAMIE MARIANO,

Plaintiff,

For: Violation of B.P Blg 22
SPINEL DECLARO,
Defendant.
x-----------------------------------------------------x
INFORMATION

complaint originally filed by the offended party, accuses SPINEL
DECLARO for having violated B.P. Blg 22, committed as follows:
That on or about and during the period comprised between
January 2, 2016 and March 2017 in the City of Manila, Philippines,
within the jurisdiction of this court, the said accused, did then and
there draw and issue Check 87232-22 and Check 238498-92 dated
February 15, 2016, purportedly in payment of loan, which upon
presentment for clearing/collection was dishonored by the drawee
bank for the reason Account Closed/Drawn against Insufficient
Fund, and which check the accused failed to replace with cash
within 5 days from notice of dishonor.
Contrary to law.
Manila, 3 April 2017.

(SGD) Earl Estacio

CERTIFICATION
Earl Estacio

2017 Manila, Philippines.
Randy David
City of Manila
Branch 44

Plaintiff,

For: Murder
EARL ESTACIO,
Defendant.
x-----------------------------------------------------x
MOTION TO QUASH
Defendant thru counsel, and unto this Honorable Court,

moves to quash the information filed against the said defendant
on the following grounds:
1. That the criminal liability of the defendants has been

extinguished;
2. That the defendant is in jeopardy of being convicted of

the offense charged.
ARGUMENTS
a) That the criminal liability of the defendant has been

extinguished.
(Here state whether such extinction of criminal liability is
founded on amnesty, pardon or marriage of the offender with the
offended party in the cases where such pardon or marriage
extinguishes criminal liability, prescription of offenses or the
penalty, and the facts constituting such extinction)
b) That the defendant is in jeopardy of being convicted of
the offense charged.
(Here state, among others, the crimes under which the
name of the court in which he was in jeopardy, and the date and
place of such jeopardy)
PRAYER
WHEREFORE, in view of all the foregoing, it is respectfully

prayed that the above-entitled information be quashed, and the
defendant be discharged.
Other just and equitable reliefs are also prayed for.
Manila for Las Pinas City, November 22, 2007.
Demetrio Sandoval
Counsel for Defendant
4th floor, Madrigal Tower, Madrigal
Business Center, Alabang,
Muntinlupa City
Attorneys Roll No. 2324
IBP 2324-01/03/08 Muntilupa
PTR 4232-01/03/08 Muntilupa
MCLE No. 23242-Nov. 17, 2007
REQUEST FOR AND NOTICE OF HEARING
The Branch Clerk of Court

Regional Trial Court
Branch 24, Las Pinas City
Please submit the foregoing Motion to the Court for its

consideration and approval immediately upon receipt hereof and
kindly include the same in the courts calendar for hearing on
November 29, 2007 at 8:30 in the morning.
Demetrio Sandoval
Atty. Conrado Manuel

Counsel for Plaintiff
2176 Alabang-Zapote Road,
Las Pinas City
Please take notice that counsel has requested to be heard on

Demetrio Sandoval
EXPLANATION OF SERVICE
Copy of the motion was served to the defendant by registered

mail due to time and distance constraints, and for lack of the
undersigneds staff who can serve the same in person.
Demetrio Sandoval
CC: Atty. Conrado Manuel

Las Pinas City
City of Manila
Branch 44

Plaintiff,

For: Murder
EARL ESTACIO,
Defendant.
x-----------------------------------------------------x
PETITION FOR BAIL
Defendant, in the above-entitled case, thru counsel, unto

this Honorable Court, respectfully states:
1. That the defendant is in custody for alleged commission

of a capital offense;
2. That no bail has been recommended for his temporary

release, on the assumption that the evidence of guilt is strong;
3. That the burden of showing that evidence of guilt is

strong is on the prosecution, and unless this fact is satisfactorily
shown, the defendant may be bailed at the courts discretion.
WHEREFOR, upon prior notice and hearing, it is respectfully

prayed that the defendant be admitted to bail in such amount as
this Honorable Court may fix.
Manila, Philippines. 3 April 2017.
Demetrio Sandoval
Muntinlupa City
MCLE No. 23242-Nov. 17, 2007


Demetrio Sandoval

Las Pinas City

Demetrio Sandoval
Copy of the petition was served to the defendant by registered

Demetrio Sandoval

Las Pinas City
Republic of the Philippines
People of the Philippines,

Plaintiff,
- Versus - Criminal Case: 1234

For: Libel
Dr. Alicia Santos and Fr. Rolly Dela Vega,

Accused.
x- - - - - - - - - - - - - - - - - - - - - - - - - - - - - -x
MOTION TO DEFER ARRAIGNMENT AND TO SUSPEND

PROCEEDING
The accused, thru counsel, states that:
1. The above entitled case is set for arraignment on June 12,

2016 at 9:00 in the morning.
2. The basis in filing the present information is the Resolution of

the Office of the City Prosecutor of Quezon City dated
February 27, 2016 and the order dated March 25, 2016.
3. On May 20, 2016, the accused filed a Petition for Review of

the said resolution before the Department of Justice, and
which petition for Review is still pending for resolution.
4. In order not to render the Petition for Review moot and

academic, and in consonance with the provision of Sec. 11,
Rule 116 of the Revised Rules of Criminal Procedure, accused
respectfully moves that his arraignment schedule on June 12,
2016 be deferred or suspended and the proceedings of the
above-entitled case be held in abeyance until the final
resolution of the Petition for Review;
5. The present motion is filed not for the purpose of delaying

early disposition of the case but to secure the accused hasty,
malicious and oppressive prosecution, and to protect him
from and open and public accusation of crime, expense and
anxiety of a public trial and also to protect the State from
useless and expensive trial.
Accordingly, premises considered, and in the interest of
justice, it is respectfully asked that the arraignment of the accused
set on June 12, 2016 and the proceedings in the present case be
deferred and suspended until the final resolution by the
Department of Justice of the Petition for Review.
Other reliefs just and equitable are likewise prayed for.
Quezon City, 26 May 2016.
Atty. Rodrigo Duterte

Counsel for the Accused
IBP 23232/Quezon City/ 1-1-11
Roll 2342432
PTR No. 232323/QC/1-1-11
MCLE Comp No. 23234
Notice and Copy Furnished:
Atty. Chato Cabigas

Clerk of Court
Office of the City Prosecutor

Quezon City
Please be notified that the foregoing motion is set for

hearing on June 2, 2005, Friday at 2:00 oclock in the afternoon.
Rodrigo Duterte
The foregoing motion was not served personally to the Clerk

of Court and for the private complainants and service by registered
mail was resorted due to distance and lack of manpower and
thereby rendering personal service inconvenient and impracticable.
Republic of the Philippines
NATIONAL CAPITAL JUDICIAL REGION
Branch 33, Cebu City
Jose Martin Ramirez,

Plaintiff,
- Versus - Civil case: 8945

For: Sum of Money with
Damages
Spouses Rodrigo and Lourdes Eala

Respondent.
x--------------------------x
EX PARTE MOTION TO SET THE CASE FOR PRE-TRIAL

CONFERENCE
Plaintiff, thru counsel, states:

1. That the records of the case will show that the defendant
had already filed his answer and no subsequent pleadings
was filed;
2. That being the last pleading, the case should already be set
for pre-trial conference pursuant to Sec. 1, of Rule 18 of
the 1997 Rules of Civil Procedure.
Accordingly, premises considered, it is requested to this Court

that the above entitled case be set for pre-trial conference.
Other reliefs just and equitable are likewise prayed for.
February 26, 2016, Cebu City.
Atty. Jason B. Evangelista

Roll of Attorney 72727
IBP No. 88282/ 11-11-16
PTR No. 202020/ 11-11-16
MCLE No. 2424/ 05-30-14
Notice and Copy furnished:
Atty. Peter Pan

Suite 123 Linden Suites Tower
Ortigas St., Pasig City
The undersigned shall submit the foregoing motion for the Courts
resolution on 15 March 2016, Wednesday at 2:00 oclock in the
afternoon.
Jason B. Evangelista
The foregoing motion was not served personally to the Clerk

of Court and for the private complainants and service by registered
mail was resorted due to distance and lack of manpower and
thereby rendering personal service inconvenient and impracticable.
City of Manila
Branch 44

Plaintiff,

For: Murder
EARL ESTACIO,
Defendant.
x-----------------------------------------------------x
MOTION TO REDUCE BAIL
Accused, thru counsel, by way of a special appearance solely

for this purpose, respectfully alleges:
1. That the accused has been charged with Murder and that
the bail for his provisional release has been set at P50,000.00;
2. That the accused is a poor fellow of very limited means

such that it is impossible for him to pay the full amount of his bond
and is therefore constrained to request for a reduction of the
amount of bail;
3. That it would be advantageous to everyone if he be given

temporary liberty thereby allowing him to continue with his gainful
employment and as head of the family with three dependents;
4. As such, accused appeals to the mercy and compassion of

this Honorable Court and respectfully requests that the bail be
reduced to P20,000.00;
5. That this motion for reduction of bail is being filed without
prejudice to any other remedy which may be available to the
accused and that the accused expressly reserves the right to
question the legality of the issuance of the search warrant or his
warrantless arrest if the circumstances would so warrant.
WHEREFORE, accused respectfully prays that his bail be

reduced to P20,000.00
Other relief just and equitable are likewise prayed for.
Manila, Philippines. 3 April 2017.

Demetrio Sandoval
Muntinlupa City
MCLE No. 23242-Nov. 17, 2007


Demetrio Sandoval

Las Pinas City

Demetrio Sandoval
Copy of the motion was served to the defendant by registered

Demetrio Sandoval

Las Pinas City

LFW3

Caricato da

Informazioni sul documento

Copyright

Formati disponibili

Condividi questo documento

Condividi o incorpora il documento

Opzioni di condivisione

Hai trovato utile questo documento?

Questo contenuto è inappropriato?

Copyright:

Formati disponibili

LFW3

Caricato da

Copyright:

Formati disponibili

TABLE OF CONTENTS

1. Criminal information for Murder

PEOPLE OF THE PHILIPPINES,

-versus- CRIMINAL CASE NO. 24242

The undersigned Assistant City Prosecutor, upon sworn

That on or about January 15, 2017 in the city of Balanga,

Bataan, Philippines. April 2, 2017

(SGD) Earl Estacio

Witnesses: 1. Ricky Flores 12 Del Monte Quezon City

Bail Recommended: P10,000

I hereby certify that the preliminary investigation in this case

SUBSCRIBED AND SWORN to before me this 3rd day of MARCH

PEOPLE OF THE PHILIPPINES,

-versus- Criminal Case: 12345

Dr. Alicia Santos and Fr. Rolly Dela Vega,

The undersigned prosecutor accuses Dr. Alicia Santos and Fr.

On or about 22 December 2015 in the City of Quezon, the

Ang kapal naman ng mukha ng eskwelahang ito, itong si

(SGD) Laurence Taguinod

Witnesses: 1. Ricky Flores 12 Del Monte Quezon City

Bail Recommended: P10,000

I hereby certify that the preliminary investigation in this case

Subscribed and sworn to before me this 27 February 2016 in

PEOPLE OF THE PHILIPPINES,

-versus- CRIMINAL CASE NO. 24242

The undersigned Assistant City Prosecutor, upon sworn

That on or about January 15, 2017 in the city of Balanga,

Bataan, April 2, 2017

Witnesses: 1. Ricky Flores 12 Del Monte Quezon City

Bail Recommended: P10,000

I hereby certify that the preliminary investigation in this case

SUBSCRIBED AND SWORN to before me this 3rd day of MARCH

YRIZ TAMIE MARIANO,

-versus- CRIMINAL CASE NO. 24242

The undersigned Assistant City Prosecutor, upon sworn

Manila, 3 April 2017.

Witnesses: 1. Ricky Flores 12 Del Monte Quezon City

Bail Recommended: P10,000

SUBSCRIBED AND SWORN to before me this 3rd day of MARCH

PEOPLE OF THE PHILIPPINES,

-versus- CRIMINAL CASE NO. 24242

Defendant thru counsel, and unto this Honorable Court,

1. That the criminal liability of the defendants has been

2. That the defendant is in jeopardy of being convicted of

a) That the criminal liability of the defendant has been

WHEREFORE, in view of all the foregoing, it is respectfully

Manila for Las Pinas City, November 22, 2007.

REQUEST FOR AND NOTICE OF HEARING

The Branch Clerk of Court

Please submit the foregoing Motion to the Court for its

Atty. Conrado Manuel

Please take notice that counsel has requested to be heard on

Copy of the motion was served to the defendant by registered

CC: Atty. Conrado Manuel

PEOPLE OF THE PHILIPPINES,

-versus- CRIMINAL CASE NO. 24242

PETITION FOR BAIL

Defendant, in the above-entitled case, thru counsel, unto

1. That the defendant is in custody for alleged commission

2. That no bail has been recommended for his temporary

3. That the burden of showing that evidence of guilt is

WHEREFOR, upon prior notice and hearing, it is respectfully

Manila, Philippines. 3 April 2017.

REQUEST FOR AND NOTICE OF HEARING