Republic of the Philippines

Second Judicial region

1st MUNICIPAL CIRCUIT TRIAL COURT
San Pablo-Sta. Maria
San Pablo, Isabela

PEOPLE OF THE PHILIPPINES,

Plaintiff,
Crim. Case No. 1412
For: Assault Upon Agent of a
-versus- Person in Authority

ALGER REYES y CANCERAN

AND REYNANTE REYES y
CANCERAN,
Accused.
x--------------------------------------x

MOTION TO REVIVE

COMES NOW, the Accused, through the Public Attorney’s

Office, unto this Honorable Court, most respectfully avers THAT:

1. On November 8, 2000, accused was charged with the crime

of Assault Upon Agent of a Person in Authority, docketed as Criminal
Case No. 1412 at the 1st Municipal Circuit Trial Court, San Pablo,
Isabela;

2. Due to the absence of the accused to appear at the

scheduled hearing, the case was archived as per Order dated
December 18, 2001;

3. Accused ALGER REYES y CANCERAN only learned that

a case was filed against him by private complainants Wilson Turingan
y Guzman and Ignacio Maraggun y Malana when he secured a
Certification from the Honorable Court; a copy of the Certification dated
July 16, 2019 is hereto attached as ANNEX “1”;

4. Accused categorically deny the complaint for they are all

product of lies and fabrications, purposely designed to harass and
malign their reputations;

1
 5. The allegations in the complaint never happened hence,
the private complainants executed an Affidavit of Desistance which
marked as ANNEX “2”;

6. In view of whereof, the plaintiff moves that the instant case

be revived and set the same for hearing for its speedy disposition.

PRAYER

WHEREFORE, in light of the foregoing, it is most

respectfully prayed of this Honorable Court to issue an Order reviving
the case and consequently issue an Order dismissing the same.
Other relief and/or remedies, just and equitable are likewise
prayed for.
Cabagan, Isabela. August 13, 2019.

DEPARTMENT OF JUSTICE
Public Attorney’s Office
Cabagan District
Cabagan, Isabela

By:

Atty. JHOEY C. BUENO

IBP OR No. 069966, 01-18-2019, Cagayan Chapter
Roll of Attorney’s No. 68725

With our conformity:

ALGER C. REYES REYNANTE C. REYES

Accused Accused

2
 NOTICE OF HEARING

THE BRANCH CLERK OF COURT

1st Municipal Circuit Trial Court
San Pablo-Sta. Maria
San Pablo, Isabela

Greetings!

Please submit the foregoing Motion for the approval and

consideration of the Honorable Court on August 20, 2019 at 9:00
o’clock in the morning.

Atty. JHOEY C. BUENO

Copy Furnished:

Pros. REMELYN A. DALAFU-TAGAO

Office of the Provincial Prosecutor
Cabagan, Isabela