Republic of the Philippines

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
Branch 78
Quezon City
PEOPLE OF THE PHILIPINES,
Plaintiff,
- versus -

Criminal Case No. R02N-15-11359-CR

ALEXANDRO VARGA
For: VIOL. OF SEC. 9(F)
a.k.a Gabriel, John, 24 years old,
OF RA 8484
Male, single, Romanian National
And temporary billeted at
Marriot Hotel
MILAH KARMILAH
a.k.a Milah Karnah, 25 years old,
female, single Indonesian National
and temporary billeted at
Marriot Hotel
Accused .
x------------------------------------------------x

MANIFESTATION WITH EXPLANATION FOR

FAILURE TO SUBMIT CERTIFICATE OF
DETENTION
ACCUSED, through counsel, and unto this Honorable
Court, most respectfully avers:
1.
That Based on Police Records, the accused were
arrested and detained last December 13, 2015 at QCPD
Kamuning Police station 10 and the cases were referred
to the Honorable City Prosecutor on December 14,
2015.
2.
Thereafter, the case was docketed for inquest with
reference XV-03-INO and the Office of the City
Prosecutor rendered a resolution recommending the

filing of the said charges and setting the amount of Bail

for their provisional liberty.
3.

That on December 15, 2015 an information

was filed charging both accused of violation of
Section 9 (F) of RA 8484 otherwise known as the
Access Device Law.
4.
That in connection with our application for Bail for
the temporary release of herein accused the
undersigned requested before the Station Commander of
QCPD Station 10 to issue a certificate of detention
attaching the respective Passport IDs of the accused.
Copy of the Letter Request and Passports received by
the police station are herein attached as Annexes A
and B for reference.
5.

That despite such request, the Station

Commander PSUPT. Pedro T. Sanchez refused to
issue a Certificate of Detention on the ground that
the passports and identity of the said accused are
needed to be verified before the Bureau of
Immigration.
6.

Thus, despite providing proof of sufficient

identity for the accused, undersigned failed to
secure the necessary Certificate of Detention.
7.

That the refusal or failure to immediately

issue the said Certificate of Detention despite
proper request and proof of identification violates
the accused right to Bail.
8.

That this manifestation is submitted in lieu of

the pendency of our request for Certificate of
Detention.
9.

That this manifestation is intended solely for

the purpose alluded thereto.
PRAYER
WHEREFORE, foregoing premises considered, it is
most respectfully prayed of this Honorable Court that the
instant manifestation be noted in lieu of the absence or
2

failure to secure a Certificate of Detention in relation to

the application for Bail of the accused.
Other just and equitable reliefs are likewise prayed
under the premises.
Quezon City, Philippines this 28th day of December 2015
Respectfully submitted.
ATTY. JAIRUS B. RUBIO
Counsel of the Accused
Roll No. 64701 4/29/15
IBP No. 1006546
MCLE Exempt
Lot 4 Blk 4 Crestwood
Subdivision,
Brgy. San Luis, Antipolo, Rizal

NOTICE OF HEARING
The Honorable Branch Clerk of Court
Regional Trial Court Branch 78
ALESSANDRO D. JURADO
Assistant City Prosecutor
Department of Justice
Quezon City
PSUPT. PEDRO T. SANCHEZ
Station Commander
Quezon City Police District
Police Station 10
EDSA, Kamuning, Quezon City
Greetings!
Please take notice that on ________________ at 8:30
oclock in the morning, undersigned counsel will submit the
foregoing Motion to the Honorable Court for its consideration
and approval. Accordingly, the Branch Clerk of Court is

respectfully requested to include said motion in the calendar

of the Court for that day. Thank you.
ATTY. JAIRUS B. RUBIO
Counsel of the Accused
Copy Furnished
ALESSANDRO D. JURADO
Assistant City Prosecutor
Department of Justice
Quezon City
PSUPT. PEDRO T. SANCHEZ
Station Commander
Quezon City Police District
Police Station 10
EDSA, Kamuning, Quezon City