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Republic of the Philippines

REGIONAL TRIAL COURT
Third Judicial Region
Malolos City, Bulacan
BRANCH 22

PEOPLE OF THE PHILIPPINES,

- versus - CRIM. CASE NO. 5232-M-2018

FOR: Violation of Sec. 11, Art. II of
Republic Act No. 9165

JOVEN REYNALDO y INGIELLO,

Accused.
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MOTION TO CORRECT ORDER DATED DECEMBER 12, 2019

ACCUSED, assisted by the Public Attorney’s Office, unto this

Honorable Court, respectfully states the following:

1. Accused was originally charged with violation of Section 11, Art. II

of Republic Act No. 9165 (“RA No. 9165”), and is currently detained
at the Bulacan Provincial Jail;

2. Accused entered a plea of GUILTY to the lesser offense of Section

12, Art. II of RA 9165;

3. Accused was sentenced to suffer the penalty of SIX (6) MONTHS

AND ONE (1) DAY TO ONE (1) YEAR IMPRISONMENT, a fine of
TEN THOUSAND PESOS (P10,000.00) and to undergo drug
dependency examination (DDE);

4. In the Order dated December 12, 2019, this Honorable Court ordered
the Jail Warden/Station Commander of the 1st Bulacan Provincial
Mobile Force Company to release the accused upon proof of payment
of the penalty of fine;

a. However, the accused is detained at the Bulacan Provincial Jail,

as shown in the latest Certificate of Detention in the records of
this Honorable Court;

b. The accused is humbly requesting this Honorable Court to

correct the said Order, and Order the Jail Warden of the
Bulacan Provincial Jail to release the accused.
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PRAYER

WHEREFORE, premises considered and for humanitarian reasons,

the accused respectfully prays to this Honorable Court that the instant
motion be GRANTED.

Other reliefs as may be deemed just and equitable under the premises
are likewise prayed for.

RESPECTFULLY SUBMITTED.

City of Malolos, Bulacan, December 11, 2020.

Department of Justice
PUBLIC ATTORNEY’S OFFICE
Malolos City, Bulacan District Office (Annex)
Ground Floor, Commercial Building,
Bulacan Provincial Capitol Compound,
Malolos City, Bulacan

By:

Atty. JOHN MARK T. ARCILLA

Public Attorney II
Roll No. 69408
IBP Lifetime Member No. 016752; 07/12/2017
MCLE Compliance No. VI-0010151; 07/06/2018

NOTICE

Ms. MA. ADORACEL B. MARCELINO

Court Interpreter/OIC
RTC Branch 22, Malolos City
Bulacan

Greetings:

Please take notice that the undersigned will be submitting the instant
Motion for the consideration and approval of the Honorable Court
immediately upon its receipt. Thank you.

ATTY. JOHN MARK T. ARCILLA

Copy furnished:
Hon. ROMMEL J. DE LEON
Office of the City Prosecutor,
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Malolos City, Bulacan