Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

8th Judicial Region
Ormoc City
-o0o-

PEOPLE OF THE PHILIPPINES

Plaintiff,
Case No. 10326
-versus- For: Violation of Batas
Pambansa Blg. 22
JESUS TINAPAY, JR.,
Accused.
x-------------------------------------x

MOTION TO CONSOLIDATE CASES

COMES NOW, the accused, Jesus Tinapay Jr., through the

undersigned counsel and to this Honorable Court, most respectfully
allege and state THAT:

1. The City Prosecutor of Ormoc City has recommended the filing

of several counts of violation of Batas Pambansa Blg. 22 (BP22)
against accused, Jesus Tinapay Jr., for the above-captioned case;

2. In effect, six (6) separate Information were filed by the City

Prosecutor of Ormoc City against herein accused before this
Honorable Court;

3. The above-entitled case is one of the six (6) cases filed against
the accused;

4. However, the defense will be presenting common witnesses

and evidence for these cases.

5. In order to serve the best interest of the parties and to settle

expeditiously the issues involved, there is a need to consolidate
the above-captioned case with Criminal Cases No. 10327, 10328,
10329, 10330 and 10331, all of which are for the Violation of
Batas Blg. 22 pending before this Honorable Court.

1
 PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed unto this Honorable Court that an Order be issued to
consolidate the above-entitled case with Criminal Cases No. 10327,
10328, 10329, 10330 and 10331, filed by the same private complainant
against the same accused which are now pending before this
Honorable Court for reasons discussed herein.

Other reliefs just and equitable in the premises are likewise

sought.

MOST RESPECTFULLY SUBMITTED. September 25, 2020,

Cebu City to Ormoc City.

SGD LAW OFFICE

Counsel for the Accused
Unit 2 G/F The Pergola Building, J. Alcantara St. Sambag I, Cebu City

ELIMER TEVES ESPINA

PTR No. 1862809/12.10.2019/Cebu City
IBP No. 24199887/12.26.2019/Cebu City Chapter
Roll of Attorney’s No. 70896
MCLE Compliance No. VI – 0023581 /Pasig City
Mobile: (0932) 8768598
Email: elimer.teves.espina@gmail.com

Copy furnished by electronic mail:

The City Prosecutor of Ormoc City
Office of the City Prosecutor
Ormoc City
Email: ocp.ormoc@gmail.com

NOTICE
The Clerk of Court
MTCC Ormoc City

Greetings! Kindly submit the foregoing Motion to Consolidate

Cases for the Honorable Court’s kind consideration without need of
further arguments or presence of counsel.

ELIMER TEVES ESPINA