REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

National Capital Judicial Region
Branch 229
Quezon City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

CRIMINAL CASE NO. R-QZN-16-09538-CR

-versus- For: Violation of Republic Act No. 9262

JOSE UY y PUA,
Accused.
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MOTION FOR ISSUANCE OF

HOLD DEPARTURE ORDER

The prosecution through the private prosecutor acting under the

control and supervision of the public prosecutor unto this Honorable Court
most respectfully avers:

1. That the accused is of pure Chinese parentage and has plenty of

relatives in China.

2. That private complainants, Maria Charo Calalo Uy and children

Maria Yna Angela Uy and Maria Yza Thalia Uy are apprehensive
that anytime during the course of the trial if accused feels that
the evidence of guilt against him is strong, there is great
possibility that he will leave the country and seek refuge in
China.

3. Relatedly, a check made with the Bureau of Immigration reveals

that accused frequents himself in going abroad, hence, he could
easily leave the country if he wants to.

4. The above mentioned criminal indictment carries a correctional

penalty which is more or less six (6) to eight (8) years
imprisonment and the same is cognizable by the Regional Trial
Courts, thus, those being tried for violation of Republic Act. 9262,
so that, we humbly submit that the issuance of a Hold Departure
Order by this court is proper and as a matter of course.
 WHEREFORE, in view of the foregoing, it is most respectfully
prayed of this Honorable Court that a Hold Departure Order against the
herein accused be immediately issued.

Quezon City, 13 January 2020.

ATTY. NARZAL B. MALLARES

No. 2 Sct. Dr. Lazcano cor. Mo. Ignacia St.
Brgy. Paligsahan, Quezon City
PTR No. 7773993/2-18-2019/Quezon City
IBP No. AR53714134/2-19-2019/Quezon City
MCLE No. VI-0017109/01-10-2019
Roll of Attorney: 29557
Cellphone No. 0906-2767254

NOTIFICATION
The Clerk of Court
RTC Branch 229
Quezon City

SACP MARIESTHER B. VEDAÑA

Public Prosecutor RTC Branch 229
Office of the City Prosecutor
DOJ Bldg., Quezon City Hall, Diliman, Quezon City

ATTY. ROGELIO G. PIZARRO JR.

1452 Quintos St. Sampaloc, Manila, 1008

Greetings:

Kindly include the foregoing motion in the January 20, 2020

calendar of this Honorable Court, so that counsel and the matter submitted
for consideration be held accordingly.

ATTY. NARZAL B. MALLARES

Noted by:

SACP MARIESTHER B. VEDAÑA

Public Prosecutor RTC Branch 229
Office of the City Prosecutor
DOJ Bldg., Quezon City Hall, Diliman, Quezon City

Copy furnished:

ATTY. ROGELIO G. PIZARRO JR.

1452 Quintos St. Sampaloc, Manila, 1008