Republic of the Philippines

REGIONAL TRIAL COCURT

Second Judicial Region
Branch 31
Cabarroguis, Quirino

PEOPLE OF THE PHILIPPINES,

Plaintiff, CRIM. CASE NO. 3918
FOR: VIOLATION OF SEC. 11
ART. II OF R.A. 9165
-versus-

NATHANIEL S. GUILLERMO,
Accused.
x--------------------------------------x

MOTION FOR RECONSIDERATION

(to the Order dated 8 October 2019)

Accused, through the undersigned counsel and unto the

Honorable Court, respectfully states:

1. That on 8 October 2019, the Honorable Court an Order

directing the Philippine National Police (PNP) Diffun, Quirino to
bring the living body of the accused to the Bureau Jail Management
Penology for documentation purposes;

2. That to be candid, the accused desire to stay in detentions for

the meantime while the case is pending in the detention facility of the
PNP, Diffun, Quirino. The detention facility of the PNP Diffun,
Quirino is more convenient to him as his family is always available
anytime to provide his medical and basic needs. There are
establishments and institutions nearby to cater the medical needs of
the accuse;

3. That moreover, his security is better looked upon inside the

PNP Diffun, Quirino detention facility;

PRAYER

Wherefore, it is most respectfully prayed tha the Order

directing the delivery of the living body of the accused to the BJMP

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be recalled and order the detention of the accused with the PNP
Diffun, Quirino while the case is pending.

Such other reliefs as are just and equitable are prayed for in the
premises.

Cabarroguis, Quirino. 16th October 2019.

Atty. MA. KAREN A. BALDONADO-GUILLERMO

Counsel of the Accused

CC:

Office of the Provincial Prosecutor

Cabarroguis, Quirino

The Clerk of Court

BRANCH 31
Regional Trial Court
Cabarroguis, Quirino

Please inform the Honorable Court that this motion is

submitted for resolutions without further oral arguments.

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