Republic of the Philippines

REGIONAL TRIAL COURT

Eight Judicial Region
Branch 9
Bulwagan ng Katarungan
Tacloban City

THE PEOPLE OF THE PHILIPPINES, Crim. Case No. 201

Plaintiff, For: Resistance &
Disobedience to an
Agent of Person in
Authority
-versus-

JUAN DELA CRUZ,

Accused.
x- - - - - - - - - - - - - - - - - - - - - - - - x

NOTICE OF CHANGE OF ADDRESS

THE CLERK OF COURT

MTCC BR. 1, Tacloban City

Greetings:

Please note the transfer of office of the undersigned, counsel

of record for the Accussed, from Massa St., Happy Ville, TAcloban
City, to:

Green Lantern St.

Brgy. Avengers
TAcloban City 6500

It is most respectfully requested that, henceforth, copies of

court decision, orders, and other processes of this honorable court
be furnished undersigned counsel in her new address given herein.

Tacloban City. 18 February 2019.

AMAYA M. MAYA
Roll No. 88888
IBP Lifetime No. 88888
PTR No. 88888; 2-18-19; Tacloban City
MCLE Compliance No. III-88888;02-18-18
Republic of the Philippines
 Republic of the Philippines
REGIONAL TRIAL COURT
Eight Judicial Region
Branch 9
Bulwagan ng Katarungan
Tacloban City

THE PEOPLE OF THE PHILIPPINES, Crim. Case No. 201

Plaintiff, For: Resistance &
Disobedience to an
Agent of Person in
Authority
-versus-

JUAN DELA CRUZ,

Accused.
x- - - - - - - - - - - - - - - - - - - - - - - - x

NOTICE OF DEATH

THE CLERK OF COURT

MTCC BR. 1, Tacloban City

Greetings:

Please be informed that accused JUAN DELA CRUZ died on

21 February 2019 in Tacloban City, evidenced by his Certificate of
Death hereto attached as ANNEX “A”.
Pursuant to Article 89 of the Revised Penal Code (RPC) of
the Philippines, death extinguishes criminal liablity. Thus, this case
shall be terminated.
RESPECTFULLY SUBMITTED, 28 February 2019 at
Tacloban City

Tacloban City. 18 February 2019.

AMAYA M. MAYA
Roll No. 88888
IBP Lifetime No. 88888
PTR No. 88888; 2-18-19; Tacloban City
MCLE Compliance No. III-88888;02-18-18
 REGIONAL TRIAL COURT
Eight Judicial Region
Branch 9
Bulwagan ng Katarungan
Tacloban City

THE PEOPLE OF THE PHILIPPINES, Crim. Case No. 201

Plaintiff, For: Resistance &
Disobedience to an
Agent of Person in
Authority
-versus-

JUAN DELA CRUZ,

Accused.
x- - - - - - - - - - - - - - - - - - - - - - - - x

TENDER OF EXCLUDED EVIDENCE

Accused through counsel respectfully tenders the following
excluded evidence:
1. a. The intended testimony of hostile witness Tinker Bell of
Brgy. Looc, Tomas Oppus, Southern Leyte, during the
intended recall of said hostile witness; and
b. The Handwritten Narrative of Tinker Bell, written in
Cebuano dialect, which contains his declarations
regarding the incident in question. A certified copy of said
Handwritten narrative is already found in the records of the
case;
c. The English Translation of said handwritten narrative of
Tinker Bell;
2. If said hostile witness had been allowed to testify on his
handwritten narrative and consequently if said handwritten
narrative had been admitted, these evidence would have
proven that:
i) Tinker Bell was deliberately telling a lie and was
trying to obstruct justice when he disowned the Joint
Affidavit (Exhibit 1) (which he actually signed) and
 disowned knowledge of the incident when in fact he
wrote a written narrative thereof which was used as
basis in the preparation of said Joint Affidavit;
ii) Accused Juan Dela Cruz was not committing a crime
when the police officer arbitrarily arrested him. The
accused was challenged and provoked to a fight by
Peter Bangs, the father of ;

As basis, accused respectfully offers the following

Arguments:
a. During the November 19, 2010 hearing, Tinker Bell
turned hostile against the accused and practically
disowned the Joint-Affidavit (Exhibit

2. Said handwritten narrative of Tinker Bell would prove that:

a. Tinker Bell was deliberately telling a lie and was trying
to obstruct justice when he disowned the Joint Affidavit
(Exhibit 1) (which he actually signed) and disowned
knowledge of the incident when in fact he wrote a
written narrative thereof which was used as basis in the
preparation of said Joint Affidavit;
b. Accused was not committing a crime when the private
complainant arbitrarily arrested him;
3. The need to present said handwritten narrative only came
about when Tinker Bell maliciously disowned the Joint
Affidavit (Exhibit 1)

WHEREFORE, accused prays that in the interest of justice:

a) Hostile witness Tinker Bell of Brgy. Looc, Tomas Oppus,
Southern Leyte, be recalled to testify on his handwritten
narrative regarding the incident in question;
 b) Accused be allowed to used said handwritten narrative
and examine the hostile witness on his handwritten
narrative regarding the incident in question;
c) Pending the recall of said hostile witness, the formal offer
of exhibits for the accused be deferred;
Other relief just & equitable under the circumstances are likewise
prayed for.
Maasin City, Southern Leyte, Philippines. February 18, 2019.

Public Attorney’s Office

Maasin District Office
Maasin City, Southern Leyte
(Counsel for accused)
by:
MISAEL J. BIDON
Public Attorney III
Roll No.45622
IBP Lifetime No.05077
MCLE Compliance No.III-
0012288
Issued April 14, 2010
Copy furnished:
Pros. Cardo Dalisay
Provincial Prosecutor
Maasin City, Southern Leyte