Republic of the Philippines

REGIONAL TRIAL COURT

7th Judicial Region
Branch 57, Cebu City

PEOPLE OF THE PHILIPPINES, CRIM. CASE No. R-CEB-19-0773-CR &

Plaintiff, R-CEB-19-0774-CR
FOR: Viol. of Sec. 5 & 11, Art. II
-versus- RA 9165

KEVIN ECHAVEZ BECBEC,

Accused.
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MOTION TO DEFER IN-PATIENT REHABILITATION

ACCUSED, through counsel and to this Honorable Court, most respectfully
moves:

1. On October 19, 2020 this Honorable Court issued an order releasing the
accused since his application for probation was granted;

2. Unfortunately, accused is ordered to undergo the Health Facility-based

Inpatient Treatment and Rehabilitation program for six (months) at the
Treatment and Rehabilitation Center-Candabong, Binlod, Argao, Cebu;

3. However, until today, the accused is yet to be brought to the said

rehabilitation center to undergo the Inpatient treatment and
rehabilitation program;

4. Furthermore, the said facility is currently full and not accepting any
patients due to the COVID-19 Pandemic, hence, he cannot be
accommodated;

5. Accordingly, accused hereby seeks the kind indulgence of this Honorable

Court, for humanitarian reasons, that the Order ordering him to undergo
In-patient rehabilitation program at the Treatment and Rehabilitation
Center, Argao, Cebu be deferred and a new Order be issued for the
immediate release of the accused.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court to issue an Order immediately releasing the accused from
detention, subject to the necessary Drug Dependency Examination that may be
required of him by this Honorable Court after his release.

Other reliefs just and equitable under the premises are likewise prayed for.

Respectfully submitted. Cebu City, Philippines. February 8, 2021.

 PUBLIC ATTORNEY’S OFFICE
(Counsel for Accused)
3 Flr. Taft Commercial Center,
rd

Metro Colon Carpark

Kalubihan, Cebu City

By:

JED CARLO S. LAZAGA

Public Attorney II
Roll No. 60047
IBP No. AR: 57122755, 1/04/2021, Cebu City
MCLE Compliance No. VI-0006349,
Valid Until April 14, 2022

NOTICE

Ms. Enid Joyce O. Cañon

Branch Clerk of Court
RTC 57, Cebu City

Please submit the foregoing Motion to the kind attention of the Honorable
Court for its consideration and approval immediately upon receipt sans
appearance of counsel.

Thank you very much.

Jed Carlo S. Lazaga

Copy furnished:

Hon. Benison Harayo

Resident Public Prosecutor
benison.harayo@gmail.com

J/SUPT. Jose Rusylvi T. Abueva

Jail Warden
Cebu City Jail-Male Dormitory
Kalunasan, Cebu City
cebucityjailmale.bjmpro7@gmail.com

Explanation: Copy of this pleading is furnished thru e-mail due to COVID-19

pandemic.