REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

_________________
_________________

_________________, Criminal Case No.

_________________
Plaintiff

~ versus ~ For: _________________

_________________
Accused

x-------------------------------------------------x

URGENT MOTION
FOR ISSUANCE OF HOLD DEPARTURE ORDER

COMES NOW, the plaintiff, by the undersigned private counsel, with the
conformity of the public prosecutor and unto this Honorable Court, respectfully
moves for the issuance of a Hold Departure Order (HDO) against the accused,
and alleges that:

1. The accused is currently employed by the Philippine National Police

(PNP). In light of this ongoing case, a Memorandum was issued to the
accused stating that the he is “reinstated to Cotabato City” until the
resolution of this case. Attached hereto is a copy of a Memorandum and
marked as Annex “A”;
2. The Memorandum was issued before the accused has submitted a copy
of his bail bond amounting _________________. Attached hereto is a copy
of the above-mentioned bail bond marked as Annex “B”’;
3. In view of the above mentioned circumstances, A Watch List Order
(WLO) against the accused has been issued by the Department of Justice
(DOJ) upon application of the plaintiff attached and marked hereto as
Annex “C”;
4. Preventing the accused fromleaving the country is proper considering
that the crime charged against him is a serious offense;
5. All precautions should be observed to ensure proper dispensation of
justice.
WHEREFORE, premises considered, it is respectfully prayed that a Hold
Departure Order be immediately issues against the accused.

_________________, November 5, 2016.

CONFORME:

_________________
Assistant City Prosecutor