ee _ Pro REPUBLIC OF THE PHILIPPINES: BTS REGIONAL TRIALCOURT 9/001. THIRD JUDICIAL REGION BRANCH 58. ANGELES CITY PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. R-ANG-20- - versus - 01126-CR For. Violation of Section 11, At Hof RA. No. 9165 EDISON NOIZA Y NUBE. x URGENT MOTION TO ISSUE ORDER FOR RELEASE ACCUSED EDISON NOIZA Y NUBE, through the undersigned Public Attorney, and unto this Honorable Court, most respectfully states that: 4. On 4 December 2020, this Honorable Court issued a Joint Order approving the plea-bargaining entered into by and tetueen the parties in the above-described Case. As a result, the tation Commander of Police Station 4, Angeles City was directed to Siete the accused on the condition that ‘Accused NOIZA had “ready served the imposed sentence of imprisonment of seven (7) sronths, paid the fine imposed, and upon submission of the result of his Drug Dependency Examination/Test. 2. Asofthe date of the filing of this Motion, Accused NOIZA has already served at least seven (7) months in detention, having been detained since 01 April 2020 in Police Station 4. Further, the ‘Accused has already served his ‘subsidiary imprisonment for the fine imposed in the amount of 210,000.00 as he is an indigent client of this Office. Likewise, his Laboratory Result dated 28 December 2020 yielded negative for the use of Methamphethamine and Tetrahydrocanabinol. Finally, Certifications dated 23 December 2020 were issued by the MTCC-OCC and RTC-OCC stating that other than the above-described cases, ‘Accused NOIZA has no other pending criminal cases. ; Copies of the said Certificate of Detention, Certificate of indigency, Laboratory Result, and MTCC-OCC and RTC-OCC Certifications are herewith attached i $ are he and made integral parts hereof as Annexes “A”, “B", “C” and “D’, respectively. ‘ Scanned with CamScannerMotion to lsue Onder of tease (Grim Case No. F-ANG-20-09126-CR \ 3. with all oe euch Accused NOIZA is deemed to have complied release. jitions imposed by this ‘Honorable Court for his: WHEREFORE, It is respectfully prayed unto, Wis Honorable Court to issue an order, directing the Station ‘Commander of, Police Station 4 of Angeles City to release Accused JERRY HATE y ‘SOLE. Respectfully submitted, 29 December 2020, in Angeles City: Philippines. PUBLIC (ATTORNEY’S OFFICE Department of Justice Counsel for the Accused Ground Floor, Chief Justice Jose ‘Abad Santos New Hall of Justice ‘New City Hall Compound, Pulung Maragul, ‘Angeles City, 2009 Telephone No. (045) 322-2398 CZARINA MAY E. BANTAY Public Attomey | PUBLIC ATTORNEY'S O! ‘Angeles City District Office GIF Chief Justice Jose Abad Santos Building, Hall of Justice, Angeles City Roll of Attorney No. 73698 IBP O.R. No. 121049, December 26, 2020 ‘Admitted to the Bar on 20 June 2019 COPY FURNISHED AND NO. OBJECTION: HON. JAIME MATEO UMLAS Received by: Hall of Justice, Pulung Maragul, : So ‘Angeles City 29 December 2020 Scanned with CamScannerRepublic of the Philippines NATIONAL POLICECOMMISSION PHILIPPINE NATIONAL POLICE. ANGELES CITY POLICE OFFICE Police Station 4 St., Balibago, Angeles City MAA. Roxas Ave. ‘isganglescpor03@amail.com CERTIFICATE OF DETENTION TO WHOM IT MAY CONCERN: This is to certify that ED! snd a resident of 506 6", Balibago, since April 01, 2020, up to present for No. R-ANG-20-01126-CR. ISON NOIZA y Nube, 22 years old, single, jobless ‘Angeles City, is currently detain in this office the case of VIOLATION OF RA 9165 with Case jssued upon request of above-named person for This certification whatever legal purpose it may serve. PCMS Willy ¢ Tandoc Desk Sergeant Scanned with CamScanner “neRepublika ng Pilipinas BARANGAY BALIBAGO UNGSOD NG ANGELES TANGGAPAN NG PUNONG BARANGAY ae BARANGAY CERTIFICATION OF INDIGENCY TO WHOM IT MAY CONCERN: this is to cory thatthe person whose name ond Persea! identification appears hereon inva resident of this Barangay. He and her ariner i renting @ space, at tere oa cgirct, Purok 12, Barangay Balibago, Angeles ‘City until November 2020. 155 A sortcfawe bith and i curently ving in the City of ‘Manila. Police Station 4 since April 1, 2020 EDISON N. NOIZA is currently detained at Barangay Certification of Residency to present for a case stated below requested for 0 ‘and the result are as follows: VIOLATION OF SEC. 11 ART II OF RA 9165 ee ce arm CASE NO. R-ANG-20-01126-CR a RTC BRANCH 58, ANGELES CITY Name: __ EDISON NOIZA y NUBE Date of Birth: OCTOBER 25, 2008 ccmeamsie Citizenship: FILIPINO cee oles: SINGLE; LIVING WITH JANET F. NONAY Contact Person of Spouse: 0948-287-6563 “0 ‘Address where the person will be staying after detention: acoso) 335 BULACAN ST. MT.VIEW, BARANGAY BALIBAGO, ANGELS CITY sroperty Owner/Lessor: ROCEILYN AGAS PINO (COUSIN) Contact Person: 0951-2950-495 Pariod of Residency: SINCE MARCH 9, 2020 TO PRESENT Findings: PER OUR ASSESSMENT, SAID PERSON BELONG TO INDIGENT FAMILY ‘This Cerlfication is being on this 23° day of December, 2020. RO! c Atested By: ‘unong Barangay Ceepnartl haa — Raymond €. Fernand Barangay Secretary Scanned with CamScanner neRepublika ng Pilipinas BARANGAY BALIBAGO LUNGSOD NG ANGELES TANGGAPAN NG PUNONG BARANGAY BARANGAY CERTIFICATION OF RESIDENCE cos TO. WHOM IT MAY CONCERN: 5 This is to certify that the person whose name and Persene lentification appears. : hereon tn Tesident of this Barangay. He and her live-in pects renting @ space at cao aere en. tos Street, Purok 12, Barangay Balibago, Angeies ‘City until November 2020. a eS se gave birth and is currently ving inthe City of ‘Manila = EDISON N. NOIZA is currently detained at Police Station # sire April 1, 2020 SoSH 1g present for a cose stated below requested for Barangay Certification of Residency and the result are as follows: amemmmont Case: VIOLATION OF SEC. 11 ART II OF RA 9165 CASE NO. R-ANG-20-01126-CR RTC BRANCH 58, ANGELES CITY Name EDISON NOIZA y NUBE ‘of Birth: OCTOBER 25, 2008 PINO satus: SINGLE; LIVING WITH JANET F. NONAY _umen Contact Person of Spouse: 0948-287-6563 so Address where the person will be staying after detention: AS BULACAN ST. MT.VIEW, BARANGAY BALIBAGO, ANGELS cry "Pm" perty Owner/Lessor: ROCEILYN AGAS PINO (COUSIN) CSE Contact Person: 0951-2950-495 SA” Pellod of Residency: SINCE MARCH 9, 2020 TO PRESENT . purpote: APPLICATION FOR PLEA BARGAINING/PROBATION This Certification is being on this 23" day of December, 2020. ie C Attested By: Punong Barangay wend Sota — Raymund ©, Fernandez Barangay Secretary Scanned with CamScannerBARANGAY BALIBAGO LUNGSOD NG ANGELES ey TANGGAPAN NG PUNONG BARANGAY SKETCH OF RESIDENCE OF EDISON N. NOIZA Located at 335 BULACAN ST. MT.VIEW, BARANGAY BALIBAGO, ANGELS CITY ‘Attested By: RAYMUND C. FERNANDEZ Barangay Secretary Scanned with CamScanner«cet P worw.quesiphil.comph_ |HOME SERVICE et PHIL DIAGNOSTICS rewersitens |ltptr sss 9071 ysoging * Day-Surgery * Dental * Pharmacy 0925 577 8378 OITA, EDISON NUBE \ 19565 Mate Age: 22 ‘Questt 17616 acrac NEGATIVE NEGATIVE 2. tae Cn AMO Teduclogat Clg Gel hale Scanned with CamScannerREPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT THIRD JUDICIAL REGION OFFICE OF THE CLERK OF COURT ANGELES CITY CERTIFICATION OM IT MAY CONCERN: This is to certify that according to the available records kept in this ~ office from 1994 to present, PENDING CRIMINAL CASE has been filed inst oueen | oa, ee | Ri, ; ee |_ CASE NO. | CHARGE BRANCH Edison Noiza Y | R-ANG-20- | Viol of Sec 11 Art IT 58 i of RA 9165 4 —! Nube 01126-CR ‘This further certifies that as of this date NO OTHER CRIMINAL CASE ‘as been filed against the abovenamed person. ‘This has been issued for any legal purpose it may serve. Angeles City, December 23, 2020. jORIE B. PANALIGAN ATTY. Clerk of Court VI BY: ATTY. DARYL YANGA y RIVERA Clerk of Court V to AD MALLARE / H. SALTA Docket Cleric Scanned with CamScannerOFFICE OF THE CLERK OF COURT AND CITY SHERIFF EX-OFICIO MUNICIPAL TRIAL COURT IN CITIES ANGELES CITY CERTIFICATION REPUBLIC OF THE PHILIPPINES THIRD JUDICIAL REGION Ww \ x ; aw yo Whom It May Concern: nis is to certify that according to the available names, records a index files kept in this isi i i le ne rds and fi ist gto the available fice Criminal Case Nols. ave been filed against __KDISON NOIZA v NUBE _ " ‘Angeles City- pending before MTCC Branch/es 1 EDISON NOZA for whatever Issued upon request of 1 purpose/s it may serve. “Angeles City, _ December 23, 2020 , {) DENIS: D. SICAT Offic Ve by: | ay x {ota DBMD Clerk IIT Prepared by: _ esau paca’ > = Scanned with CamScanner