Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Branch ____, ______________ City

PEOPLE OF THE PHILIPPINES,

Plaintiff, CRIM. CASE NO. C-100823 and C-
100824
– versus – FOR: Acts of Lasciviousness in
relation to Section 5 (b) of R.A.
ROLANDO SALINAS y ESTRADA, No. 7610
Accused.
x-------------------------------------------x

MOTION FOR LEAVE OF COURT

TO FILE DEMURRER TO EVIDENCE

COMES NOW, the accused ROLANDO SALINAS y ESTRADA, assisted by the

______________________________, through the undersigned ________________________, and unto
this Honorable Court, most respectfully avers:

1. That this Honorable court had already made a ruling on the prosecution’s
formal offer of evidence on February 15, 2019;

2. That the prosecution’s evidence is inherently weak, unsubstantiated, and

insufficient to prove the guilt of all the accused beyond reasonable doubt; and

3. That in view thereof, the defense prays that it be allowed by this Honorable
Court to file its demurrer to evidence WITH LEAVE OF COURT to be able to
point out in detail the weakness of the prosecution’s evidence necessitating
the dismissal of this case and so as not to further waste the precious time of
this court.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court that the instant motion be GRANTED, allowing herein accused,
through counsel, to file a DEMURRER TO EVIDENCE, with leave of court.

Other reliefs and remedies available under the premises are likewise prayed
for.
Caloocan City. February 19, 2019.

ATTORNEY

ATTY. ___________________________
Branch Clerk of Court
Regional Trial Court
Branch _________________

Greetings:
 Please submit the foregoing motion for the kind consideration and approval
of this Honorable Court on FEBRUARY 22, 2019 (FRIDAY) at 8:30 o’clock in the
morning.

ATTY. ______________________

Copy furnished:
ACP ____________________________________
Public Prosecutor
Office of the City Prosecutor
____________________________
_______________________________