Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
STAR CITY
Branch 000

PEOPLE OF THE PHILIPPINES

- versus - CRIM. CASE Nos. 10-000-000

DINA HINA Y HANAP,

Accused.
x-----------------------------------------x

MOTION FOR LEAVE OF COURT TO FILE DEMURRER

TO EVIDENCE

Accused, DINA HINA Y HANAP, through the undersigned counsel and unto
this Honorable Court, most respectfully states that:

1. On 11 July 2019, the Honorable Court issued an Order admitting Exhibits

“A” to “Y”, inclusive of sub-markings, of the Prosecution for the purpose for
which they are being offered;

2. Considering that the Prosecution already rested with their pieces of

evidence, the accused prays for leave of court to file their Demurrer to
Evidence; and

3. It is the humble position of the Defense that the evidence presented by the
Prosecution was insufficient to prove the guilt of the accused beyond
reasonable doubt.

PRAYER

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

Honorable Court that the Motion for Leave of Court to File Demurrer to Evidence
be GRANTED and that the defense be given fifteen (15) days to file its Demurrer
to Evidence.

Star City, 01 August 2019.

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