Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 282, Valenzuela City

PEOPLE OF THE PHILIPPINES

-versus- Criminal Case No. 889-V-19

For: Violation of Sec. 11, Art. II, RA
ERWIN JOSEPH BAUTISTA y 9165
ENRIQUEZ,
Accused.
x----------------------x

NOTICE OF APPEAL

The above-named accused, with the assistance of the Public

Attorney’s Office, unto this Honorable Court hereby files this notice and
avers as follows:

1. The Honorable Court promulgated a decision on 14 September 2020

in which it found the above-named accused guilty beyond
reasonable doubt of violation of Sec. 11, Art. II, RA 9165 and
sentenced him to suffer the indeterminate penalty of imprisonment
for twelve (12) years and one (1) day as minimum and fourteen
(14) years as maximum, as well as to pay a fine of three hundred
thousand pesos (P300,000.00).

2. Accused would like to appeal the decision of the Honorable Court for
being contrary to the evidence on record, the law and established
jurisprudence. He further prays that he be exempted from the
payment of appeal fee in accordance with Section 16-D of R.A. 9406
which provides that: “The clients of the PAO shall be exempt from
payment of docket and other fees incidental to instituting an action
in court and other quasi-judicial bodies as an original proceeding or
on appeal”. The said provision was echoed in OCA Circular No. 121-
2007 (amending OCA Circular No. 67-2007), which mandated the
exemption of indigent clients of PAO from payment of docket and
other fees. In this connection, the defense implores the Honorable
Court to give due course to the appeal of the accused without
requiring him to pay a fee for the perfection thereof.

Valenzuela City, Metro Manila, 14 September 2020.

ERWIN JOSEPH BAUTISTA y ENRIQUEZ

 Accused

With the assistance of:

VALENZUELA DISTRICT OFFICE

1 Floor, Metropolitan Trial Court Bldg.
st

Justice Hall Compound, C.J. Santos St., Poblacion II,

Malinta, Valenzuela City

Through:

ATTY. RAFAEL D. PANGILINAN

Public Attorney II
Roll No. 64684
IBP OR No. 035862 dated 8/1/18 / CALMANA
MCLE Compliance No. VI - 0006876 dated 3/20/18

Noted:

ATTY. DENNIS C. KUONG

Public Attorney III/Officer-in-Charge
Roll No. 56805
IBP No. 1002981 / CALMANA / 4/13/2015
MCLE Compliance VI – 0006871 / 03/20/2018

Copy furnished:
ACP Aileen S. Agacita
Office of the City Prosecutor of Valenzuela City