REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

THIRD JUDICIAL REGION
OFFICE OF THE EXECUTIVE JUDGE
CABANATUAN CITY

THE PEOPLE OF THE PHILIPPINES

Plaintiff,

-versus- CRIM. CASE Nos. 35549, 35550,

35551-AF

ALFREDO MUÑOZ JR. y Adrineda,

Accused.
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EX-PARTE MOTION TO ALLOW

ATTENDANCE IN THE WAKE OF HIS MOTHER

ACCUSED, assisted by Public Attorney’s Office, unto the Honorable Court,

most respectfully alleges:

1. That the accused ALFREDO MUÑOZ JR. y Adrineda is presently

detained at the Bureau of Jail Management and Penology, Kalikid Sur, Cabanatuan
City, Nueva Ecija;

2. That, the mother of the accused, NEMESIA ADRINEDA MUÑOZ

died on January 21, 2023 and presently lying at their residence at Bantug Bulalo,
Cabanatuan City.

Copy of her Certificate of Death is hereto attached and marked as Annex

“A”;

3. That, the interment will be held on January 29, 2023 at 8 o’clock in

the morning;

4. That, it is the good intention of the accused to at least pay his last
respect to his good mother before she is finally laid to rest;

5. That the accused humbly requests this Honorable Court to allow him
to attend the wake of his mother on January 27, 2023 (Friday) from 8:00 o’ clock
in the morning until two o’clock in the afternoon.

5. That, accused undertakes to abide with all the conditions that the
Honorable Court may impose on him.
 PRAYER

WHEREFORE, in the interest of justice and for humanitarian reasons, it is

most respectfully prayed of this Honorable Court that accused ALFREDO
MUÑOZ JR. y Adrineda be allowed to attend the wake of his mother on January
27, 2023 (Friday) from 8:00 o’ clock in the morning until 2 o’clock in the
afternoon at Bantug Bulalo, Cabanatuan City.

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

Cabanatuan City, January 26, 2023.

Respectfully submitted.

PUBLIC ATTORNEY’S OFFICE

Counsel for the Accused
Cabanatuan City District Office
2nd Floor, Hall of Justice Bldg.,
Maharlika Highway, Cabanatuan City, Nueva Ecija

By:

Glino Barsen G. Claudio

Public Attorney II
Roll No. 67912
MCLE Compliance No.: VI-0006515
IBP Lifetime No. 017328

The Clerk of Court

Regional Trial Court
Office of the Executive Judge
Cabanatuan City

Greetings :

Kindly submit the foregoing motion to the Honorable Court for its
consideration and approval immediately upon receipt hereof.

GBGC

Copy Furnished:

______________________
City Prosecutor’s Office
Justice Hall Building,
Cabanatuan City