REPUBLIC OF THE PHILIPPINES

Regional Trial Court

7th Judicial Region
Branch 25
Danao City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- CRIM CASE. NO. DNO-15517-MV

FOR: Rape

RYAN BITOON
Accused.
X - - - - - - - - - - - - - - - - - - - - - -/

MOTION FOR LEAVE OF COURT TO FILE

DEMURRER TO EVIDENCE

The ACCUSED, through the undersigned counsel, most

respectfully states:

1. That the prosecution has presented its witnesses and has

formally offered its evidence;

2. That the admissibility of exhibits so offered had been

resolved in the order dated October 16, 2023 which was
received by the undersigned counsel on November 9,
2023;

3. That the accused seeks leave of court to file a Demurrer

to the Evidence on the ground that the evidence
presented by the prosecution is not sufficient to warrant
a conviction of the guilt of the accused beyond
reasonable doubt;

4. That this motion is filed in good faith and for the purpose
of delaying the proceedings of this case;

WHEREFORE, premises considered, it is most

respectfully prayed that the accused be granted Leave of Court
to file a Demurrer to Evidence.
 Respectfully submitted this 13th day of November 2023 at
Cebu City for Danao City, Philippines.

CHRISTOPHER S. PARAGAMAC
Counsel for Accused
Roll of Attorneys No. 82808
IBP Member’s No. 230667/ 06.09.2022/ Cebu Province
PTR No.1025659/ 01.03.2023/ Cebu Province
MCLE Compliance Certificate No. ( Exempt under MCLE Board
No. 1-2008)
Email: chrismacz1978@gmail.com
Contact No. 09399308544

COPY FURNISHED:

Pros. Raymund J. Gultiano

Deputy City Prosecutor
Office of the City Prosecutor
Danao City, Cebu, Philippines