Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
Branch 13
Davao City

PEOPLE OF THE CRIMINAL CASE NO. R-DVO-19-

PHILIPPINES, 02509-CR & R-DVO-19-02510-CR

-versus-
FOR: VIOL. OF SEC. 5, 1ST PAR. IN
CLINT SIMEON ALCORDO, REL. TO SEC. 25, ART. II,
Accused. AND SEC. 11, 2ND PAR. SUB-
PAR. NO. 3, IN REL. TO SEC.
25, ART II OF R.A. NO. 9165,
AS AMENDED BY R.A. NO.
10640
x- - - - - - - - - - - - - - - - - - - - - - -x

MANIFESTATION WITH URGENT MOTION TO

TRANSFER DETENTION

COMES NOW, the Accused, through the undersigned counsel and

unto this Honorable Court, respectfully moves for the immediate transfer
of the place of detention of the Accused from Ma-a City Jail – Main
Building to Ma-a City Jail – Annex Building, and states that:

1. Accused, CLINT SIMEON ALCORDO, is presently detained at

Ma-a City Jail – Main Building after he was committed on 14 June 2019;

2. Accused was diagnosed and is suffering from Asthma, as shown in

the herein attached Medical Certificate dated 05 May 2019 issued by his
attending physician Dr. Soo Rah Angelle R. Kwak. Copy of which is hereto
attached as Annex “1”;

3. Accused is in urgent need to be transferred to Ma-a City Jail – Main

Building considering his current medical condition;

1
 4. Accused’s Asthma might worsen if he will be allowed and continued
to stay and be confined at Ma-a City Jail – Main Building considering the
intolerable and inhuman congestion of the said detention facility, putting
thereof his life and health at greater risk;

5. It is therefore prayed that in resolving this instant motion, the

Honorable Court takes principal consideration of the compelling reasons,
as stated above;

6. The filing of this Manifestation with Urgent Motion is done in good

faith, and is not intended to delay the court proceedings;

PRAYER

WHEREFORE, premises considered, it is respectfully prayed that

the instant Manifestation with Urgent Motion be resolved urgently, and
that the Honorable Court issue an Order directing the BJMP City Jail
Warden to IMMEDIATELY TRANSFER the Accused from Ma-a City Jail
– Main Building to Ma-a City Jail – Annex Building.

In the City of Davao, Philippines, 14 June 2019.

LUMBATAN* CABADING LAYOG & PINTO LAW OFFICES

*Atty. Alexis M. Lumbatan – On Leave
Counsel for the Accused
LUMBATAN LAW
Door G-10, Genesis88 Bldg.,
Eco West Drive, Ecoland, Davao City
Telefax No. (082) 296-4114
lumbatanlaw@gmail.com

By:

KAREN CATE ILAGAN PINTO

IBP No. 057057 - 12/17/18 - Davao City
PTR No. 1477495 - 12/04/18 - Davao City
Roll of Attorney No. 70440
MCLE Compliance No. VI-0009775 - 06/07/18 - Davao City

2
 NOTIFICATION

THE CLERK OF COURT

RTC, Branch 13
Davao City

THE CITY PROSECUTOR

City Prosecution Office
Davao City

Greetings!

Please be notified that the undersigned counsel will submit the

foregoing Manifestation with Urgent Motion to Transfer Detention for
the consideration and approval of this Honorable Court, after the same
be heard immediately upon receipt hereof, sans appearance of the
undersigned counsel.

KAREN CATE I. PINTO

Copy Furnished:

THE CITY PROSECUTOR

Office of the City Prosecution
Hall of Justice
Davao City
Received by: ___________
Date received: __________