Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

First Judicial Region
BRANCH 2
Baguio City

THE PEOPLE OF THE

PHILIPPINES,
Plaintiff, CRIM. CASE No. 136105

For:
- versus -
VIOLATION of SECTION
6 of RA No. 8485
JOEFFREY (JOE) PASOS,
Accused.
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MOTION for LEAVE of COURT to FILE a

DEMURRER to EVIDENCE

WITH DUE RESPECT to the HONORABLE

COURT, the Accused, through counsel, dutifully states
that:

1) The prosecution has already presented its

witnesses and has formally offered its evidence
during the last hearing of the above-entitled case on
20 March 2018;

2) The admissibility of the evidence presented was

likewise resolved in open court during the said date;

3) The accused now seeks leave of court to file a

Demurrer to the Evidence, on the ground that the
evidence presented by the prosecution is not
sufficient to warrant a conviction of guilt of the
accused beyond reasonable doubt;

4) The motion is not intended to delay the early

disposition of this case.

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 PRAYER

WHEREFORE, premises duly considered, it is most

respectfully prayed of this Honorable Court to grant leave
to the Accused to file his Demurrer to Evidence pursuant
to Section 23 (4), Rule 119 of the Rules of Court.

Other reliefs, just and equitable, are likewise prayed

for.

This 21st day of March 2018, in the City of Baguio,

Philippines.

A B S LAW OFFICES
Suite 305, Laperal Building
Session Road, Baguio City
Tel. No. (074) 442 8243

By:

PATRICIA MARIE FRANCES D. CASTRO

PTR No. 3398888/12.11.2017/Baguio City
IBP Lifetime No. 012653/04.04.2014/Baguio City
MCLE Compliance No. V – 0002740
Roll No. 63622

NOTICE

The BRANCH CLERK of COURT

Municipal Trial Court in Cities – Branch 2
Baguio City

OFFICE of the CITY PROSECUTOR

Justice Hall, Baguio City

Greetings:

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 Please take notice that on 28 March 2018, at 8:30
o’clock in the morning, or as soon thereafter as counsel
and the matter may be heard, the undersigned will submit
the foregoing Motion for Leave of Court to File a
Demurrer to Evidence, for the approval of the Honorable
Court.

PATRICIA MARIE FRANCES D. CASTRO

COPY FURNISHED:

OFFICE of the CITY PROSECUTOR

Justice Hall, Baguio City

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