Republic of the Philippines

Province of Apayao
6th MUNICIPAL CIRCUIT TRIAL COURT
KABUGAO-CONNER
Second Judicial Region
Kabugao, Apayao

PEOPLE OF THE PHILIPPINES, CRIM. CASE NOs. 346-2023-CR

Plaintiff 247-2023-CR & 348-2023-CR

-versus- For:
FALSIFICATION OF PUBLIC
DOCUMENTS (Art. 172, RPC)
IAN LABO y DEO
(Purok 05, Bulanao, Tabuk City
Kalinga)
Accused.

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

MOTION FOR LEAVE OF COURT

TO FILE DEMURRER TO EVIDENCE

Defendant, through counsel, unto this Honorable Court, most respectfully

states:
1. That the prosecution in the above entitled case has already rested its case.

2. That the defense believes that the evidence of the prosecution against the
accused is insufficient to establish the guilt of the accused beyond
reasonable doubt and to establish his conviction, thus, the defense prays for
leave to file demurrer to evidence in accordance with Section 33 Rule 113
of the Rules of Criminal Procedure;

3. The defense prays that it be allowed by this Honorable Court to file its
demurrer to evidence WITH LEAVE OF COURT to be able to point out in
detail the weakness of the prosecution’s evidence necessitating the dismissal
of this case and so as not to further waste the precious time of this court

4. That this Motion is filed in good faith and not for the purpose of delaying the
proceedings of this case.

PRAYER
WHEREFORE, premises considered, it is respectfully prayed of this Honorable
Court that the instant motion be GRANTED, allowing herein defendant, though
counsel, leave of court to FILE A DEMURRER TO EVIDENCE within 10 days upon
notice.
Other relief and remedies available under the premises are likewise prayed for.
Tuguegarao City, this 25th of May 2024.

ATTY. NICHOLO RUDOLF A. SUPNET

Counsel for Defendant
Roll No. 54755
PTR No. TUG3194871/01-13-23/Tuguegarao City, Cagayan
IBP No. Lifetime No. 011542/Tuguegarao City, Cagayan
MCLE Complied (Certificate not yet issued)
Stall No. 3 Mama Remedios Food Hub CHO-LAW COMPOUND
67 Balzain East, Tuguegarao City, Cagayan 3500
405 Gomez St., Carig Sur, Tuguegarao City, Cagayan
0916-946-3428 nrsupnet@gmail.com

NOTICE

To: The Branch Clerk of Court

SIR/MADAME:

Greetings!

Please be notified that this Motion will be submitted for consideration and
approval of this Honorable Court upon receipt thereof without further argument, the
appearance of counsel is hereby waived

Thank you!

ATTY. NICHOLO RUDOLF A. SUPNET

Copy furnished:

PROS. CYRIL M. DEZA

State Prosecutor on case
opp_lunaapayao0817@yahoo.com

EXPLANATION FOR SERVICE BY ELECTRONIC MAIL

In compliance with Section 11 of Rule 13 of the 1997 Rules of Civil Procedure, undersigned
counsel respectfully manifests that the foregoing MOTION is being served by ELECTRONIC mail on the
e-mail addresses of counsels because of time and distance constraints, which render personal service
impracticable.

ATTY. NICHOLO RUDOLF A. SUPNET