REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

10th Judicial Region
BRANCH 10
City of Smiles

PEOPLE OF THE PHILIPPINES CRIM. CASE NO. 12345-12

Plaintiff,
For: VIOLATION OF SECTION
-versus- 4(a) OF RA 9995

MAMBO BHOSO
Accused

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MOTION FOR RECONSIDERATION

ACCUSED MOVANT, by counsel most respectfully states that:

1. Counsel for the accused received on June 18, 2022 a copy of the Judgment dated
June 16, 2022 issued by the Honorable Court;

2. The accused was found by the Honorable Court guilty of the crime of violation of
Section 4(a) of R.A. 9995 and was meted a penalty of Six (6) years and One (1)
day to Seven (7) years of imprisonment, and a fine of P 350,000.00. Accused is
also credited of the period that he is under preventive detention;

3. Counting the date of the detention of the accused from September 1, 2014 to date,
the accused have been in detention for Eight (8) years, Nine (9) months and
Eighteen (18) days. The accused likewise earned good conduct while in detention
and for all intents and purposes have served his sentence;

4. The accused is financially in distress, poor and destitute, has no property and
could not afford the P 350,000.00 fine meted by the Honorable Court;

5. The Judgment has not attained finality and may be modified by the Honorable
Court to allow subsidiary imprisonment for the unpaid fine due to the insolvency
of the accused;

WHEREFORE, it is most respectfully prayed to this Honorable Court that the

Judgment in the above-entitled case be partially modified to allow subsidiary
imprisonment for the penalty of P 350,000.00 fine meted by the Court. It is likewise
prayed that an Order of Release of the accused who have served more than the maximum
penalty of imprisonment imposed by the Honorable Court.

Other reliefs that are consistent in law and equity are likewise prayed. June 25 th, 2022
in Smiles City, Happiness.
 ATTY. FLORENTINE T. GARAY

Counsel for the Accused/Movant

Roll No. 65136; IBP Lifetime No. 015158

PTR No. 6430077, 01-03-2018; TIN-199-588-890

MCLE Compliance No. VI - 0001711

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