Republic of the Philippines

REGIONAL TRIAL COURT

Fourth Judicial Region
Branch 52
Puerto Princesa, Palawan

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. 38820

Plaintiff,

-versus- For

JOSE TALAPIAN y REYES ROBBERY under Article 299 par. (a)

Accused. (2) of the Revised Penal Code as
amended by Sec. 79 of RA 10951

x-------------------------------------x

PROPOSAL FOR PLEA BARGAINING

Accused JOSE TALAPIAN y REYES, through the undersigned Public

Attorney, unto this Honorable Court, most respectfully aver that he is being charged
with Robbery, to which he entered his plea of not guilty.

The accused now respectfully begs the indulgence of this Honorable Court that
he be allowed to plead guilty to the lesser offense of Theft under Article 309 par. 5 of
the Revised Penal Code, as amended by Sec. 81 of RA 10951 1. The pure intention of
this proposal is to make the accused eligible for availing the privilege provided under
Article 88a of the Revised Penal Code as amended by RA 11362 (Community
Service).

The accused also prays that he be allowed to withdraw his previous plea of not
guilty to the felony of Robbery and that he be re-arraigned for the lesser offense of
Theft under Art. 309 par. 5 of the Revised Penal Code as amended by RA 10951,
after the consent of the Private Complainant and the Public Prosecutor shall have
been secured.

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

Honorable Court that the instant Motion be duly APPROVED and GIVEN DUE
COURSE by allowing the accused to plead guilty to the lesser offense of Theft under
Art. 309 par. 5 of the Revised Penal Code, as amended.

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

This ___ day of May 2023, at Puerto Princesa City, Palawan.

RESPECTFULLY SUBMITTED.

Department of Justice
1
Art. 309. Penalties. – Any person guilty of theft shall be punished by:
xxx
5. Arresto mayor to its full extent, if such value is over Five hundred pesos (P500) but does not exceed Five
thousand pesos (P5,000.00).

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 PUBLIC ATTORNEY’S OFFICE
By:

TEODORO JOSE M. BRUNO III

Public Attorney I
PAO, Puerto Princesa City
Roll of Attorneys No. 76013

With my full understanding and conformity

JOSE TALAPIAN Y REYES

NOTICE

Officer-in-Charge
Regional Trial Court Branch 52
Puerto Princesa City

GREETINGS!

Please submit the foregoing motion upon receipt hereof for the approval and consideration of
this Honorable Court without further oral argument.

Thank you.
TEODORO JOSE M. BRUNO III

PROS. JHACIEL S. JUANICO-QUICHO

Office of the City Prosecutor
DOJ Bldg., Hall of Justice Compound
Sta. Monica Heights, Puerto Princesa City

GREETINGS!

Please take note that the foregoing motion will be submitted for the approval of this
Honorable Court without further oral argument.

Thank you.
TEODORO JOSE M. BRUNO III

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