Republic of the Philippines

COURT OF APPEALS
Manila

People of the Philippines

Petitioner,
G.R. No. 000002
-versus-

Honorable Judge Marjorie Nolasco,

Respondent.

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OMNIBUS MOTION FOR RECONSIDERATION AND TO

ADMIT ATTACHED AMENDED PETITION FOR CERTIORARI
UNDER RULE 65

The petitioner through the Public Prosecutor and unto this

Honorable Court respectfully states that:

1. The Regional Trial Court of Makati Branch 1 through

Honorable Marjorie Nolasco, promulgated its decisions on
the case of Special Complex Crime of Kidnapping and
Serious Illegal Detention with Rape and Homicide on 6
April 2019, finding the accused guilty beyond reasonable
doubt of the crime of Kidnapping and Serious Illegal
Detention.

2. On 13 April 2019, the Motion for Reconsideration filed by

the Office of the Public Prosecutor for the evaluation of the
pieces of evidence with respect to the crime of Rape and
Homicide was denied.
 3. On 22 April 2019, a Petition for Certiorari under Rule 65
was filed by the Office of the Public Prosecutor through the
undersigned counsel, a copy thereof was likewise served
and duly received by the Respondent via electronic mail.
However due to the oversight and inadvertence of the other
counsels, the pieces of evidence and Annexes were not
attached.

4. On 27 April 2019, this Honorable Court ordered for the

amendment of the Petition for Certiorari under Rule 65
and for the attachment of the Annexes.

PRAYER

WHEREFORE, in the interest of justice and factual

reasons above, it is most respectfully prayed of this Honorable
Court, that this Motion to Admit the Amended Petition for
Certiorari be granted. Any other reliefs that are just and
equitable under the premises are likewise being prayed for.

Manila City, 29 April 2019

ATTY. ANDREW LASTROLLO

Public Prosecutor