Republic of the Philippines

DEPARTMENT OF JUSTICE
OFFICE OF THE CITY PROSECUTOR
rd
3 Floor, DOJ Building, D.A. Compound, M. Velez Street, Guadalupe
6000 Cebu City

PROS. ROGELIO D. DEL PRADO

Handling Prosecutor

CLIFFORD EWICAN SABAS, NPS DOCKET NO. VII-09-E-INQ-21E-

Complainant, 02527

-versus- FOR: FRUSTRATED MURDER

VELLIEFLOR LAPOT MADDEN,

Respondent.
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MOTION TO RESOLVE
MOTION FOR RECONSIDERATION

COMES NOW, private complainant-movant, by the undersigned counsel,

unto this Honorable Court, most respectfully moves to resolve the movant’s
Motion for Reconsideration which was timely filed on sometime in the month
of May 2021 so that he would be able to elevate this case to a higher forum
should the resolution be unfavorable to him.

It is the intention of the movant to appeal this case to a higher tribunal

for purposes of getting justice after this case has been dismissed for lack of
probable cause despite the wounds and severe bleeding he sustained after
being stabbed, with intent to kill, by the respondent.

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

Honorable Court that the Motion for Reconsideration be now resolved for
justice sake.

Other just and equitable relief is also prayed for by the movant.

Tuburan, Cebu (For Cebu City), Philippines. June 30, 2021.

 RODULFO D. DACALOS, JR.
Counsel for the Movant
Roll No. 53243
Municipal Hall of Tuburan
Tuburan, Cebu
Mobile No. 0917.776.0848
E-mail Address: rdacalosjr@gmail.com
PTR No. 400935, Jan. 10, 2021, Cebu City
IBP OR No. 22134, Jan. 10, 2021, Cebu City Chapter
MCLE Compliance No. VI-0023574 (Aug. 22, 2019)

NOTICE

The Receiving Clerk

City Prosecutor’s Office
Cebu City

Greetings!

Please submit the foregoing motion for the consideration and approval
of the Honorable Prosecutor immediately upon receipt hereof sans arguments
and appearance of counsels.

Rddacalos, jr.

Copy furnished:

Vellieflor L. Madden
Respondent
Gate No. 3, San Carlos Heights Subdivision
Quiot Pardo, Cebu City

Police Major Janelito Marquez

PNP Station 10
Katipunan Street, Labangon
Cebu City
e-mail address: polstn10@yahoo.com/pols10@yahoo.com

Office of the Court Administrator

Supreme Court of the Philippines
Ermita, Manila
e-mail address: pio.sc@judiciary.gov.ph
Sec. Menardo I. Guevarra
Department of Justice
Padre Faura Street
1000 Manila
e-mail address: osec.inout@gmail.com

Copies of the foregoing have been served through electronic mail and
registered mail due to lack of personnel to effect personal service.

RDDACALOS, JR.