Republic of the Philippines

REGIONAL TRIAL COURT

XXXXXXXXXXXXXXXXX
Branch X
Xxxxx, XXXXXXXXX

THE PEOPLE OF THE CRIM. CASES NOS. xxxx;

PHILIPPINES, xxxx; and xxxx
Plaintiff,

-Versus- -For-

XXXXXXXXXXXX VIOL. OF SECTIONS 5, 11, &

XXXXXXXX 12, ART. II OF R.A. 9165
Accused.
X-------------------------------X
URGENT EX-PARTE MOTION TO ALLOW THE ACCUSED
TO BE BROUGHT OUT OF PENAL PREMISES TO ATTEND
BURIAL RITES OF HIS CHILD

COMES NOW, the accused through the undersigned counsel

from the Public Attorney’s Office and unto this Honorable Court, most
respectfully avers:

1. That the above-named accused is presently detained at the

XXXXXXXXXX Provincial Jail pending trial of the above-captioned
cases before this Honorable Court;

2. That per information received from the mother of the

accused, XXXXXX XXXXXX XXXXXX, the three-year old baby
daughter of accused, died just this afternoon and is scheduled to be
buried tomorrow in accordance with Islamic rites at 1:00 in the
afternoon at Barangay XXXXX, XXXXXX, XXXXXXXXXXXX;

3. That accused desires to be with her deceased daughter

today and to attend the scheduled burial rites tomorrow.

PRAYER

WHEREFORE, premises considered, and for humanitarian

consideration, it is most respectfully prayed that this motion to allow
the accused to be brought out of the XXXXXXXXXXX Provincial Jail for
the said purposes be granted.

MOST RESPECTFULLY SUBMITTED.

1
 08 June 2018. XXXXXX,XXXXXXXXX Philippines.

PUBLIC ATTORNEY’S OFFICE

Department of Justice
XXXXXXXXX District Office
XXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXX

By:

ATTY. XXXXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXX
Roll No. XXXXX
IBP No. XXXXXXXXXXXXXXXXXXX
MCLE Compliance No. IV-XXXXXXXX; XX/XX/XXXX
MCLE Compliance No. V- XXXXXXX; XX/XX/XXXX
X---------------------------------------------------------------------------------X
NOTICE OF HEARING

THE CLERK OF COURT

IN THE REGIONAL TRIAL COURT OF XXXXXXXXX
BRANCH X
XXXXXX, XXXXXXXXX

Greetings!

Please kindly submit the foregoing motion for evaluation and

consideration of the Honorable Court immediately upon receipt
without further oral argument.

RESPECTFULLY SUBMITTED.

08 June 2018. XXXXXXXX, XXXXXXXX, Philippines.

PUBLIC ATTORNEY’S OFFICE

Department of Justice
XXXXXXXXXXX, District Office
XXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXXXXXXXXX

BY:

ATTY. XXXXXXXXXXXXXXXXXXXXXXXXX
XXXXXXXXXXXXXXXX

Copy furnished through personal service:

OFFICE OF THE PROVINCIAL PROSECUTOR