REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Branch 000, STAR CITY

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus-
CRIM. CASE NO. 2017-00101
For: Violation of Section 1(a) PD
1602 as amended by Sec. 3 (c) RA
9287
BABY DELOS SANTOS
Accused.
x------------------------------------------------x

MOTION FOR ISSUANCE OF RELEASE ORDER

ACCUSED, through undersigned counsel and unto this Honorable

Court, most respectfully states THAT:

1. In the order of the Honorable Court dated 25 August 2017, it sentenced

the accused of imprisonment of thirty (30) days.

2. The accused has been detained at Star City Police Station, Custodial
Facility on August 10, 2017 as evidenced by Certificate of Detention dated 10
September 2017 signed by Police Senior Inspector Conan attached as ANNEX
“A”.

3. The undersigned beseech the indulgence of the Honorable Court to

issue a release order since the accused had already served its sentence.

PRAYER

WHEREFORE, it is most respectfully moved and prayed of this

Honorable Court to issue a Release Order to accused Baby Delos Santos.

Star City, Philippines, 10 September 2017.

By:
 JAYMEE R. QUINOA
Counsel for the Accused
Roll No. 7777
IBP No. 212121
MCLE Compliance No. VI-11-11-11

NOTICE

The Branch Clerk of Court

Regional Trial Court, Branch 000
Star City

Greetings:

Please submit the foregoing Comment for the kind consideration of the Honorable Court
immediately upon receipt hereof.

JAYMEE R. QUINOA
Public Attorney II

Copy Furnished:

Prosecutor Romeo N. Dulyet

Office of the City Prosecutor
Star City