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REPUBLIC OF THE PHILIPPINESREGIONAL TRIAL COURT

National Capital Judicial RegionBranch 1Manila

PEOPLE OF THE PHILIPPINES,Plaintiff,

Criminal Case No: 123456-versus- For: Serious Illegal Detention

JANET LIM-NAPOLES,Accused.

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INFORMATION

The undersigned, provincial prosecutor, upon sworn complaintoriginally filed by the offended party, accuses Janet Lim-Napoles of thecrime of SERIOUS ILLEGAL DETENTION, committed as follows:

That on or about January 4, 2010 in the City of Manila, Philippines,within the jurisdiction of this Court, the said accused, being a privateindividual, did then and there willfully, unlawfully and feloniously, kidnapand detain one Benhur Luy in the house of John Ponching Benrile for a

period of five days thereby, depriving said Benhur Luy of his personal

liberty and all against his will, with intent to extort ransom from the relativesof the latter.

CONTRARY TO LAW.

(sgd) Roger PingrisAsst. City Prosecutor

CERTIFICATE OF PRELIMINARY INVESTIGATION

I hereby certify that a preliminary investigation in this case wasconducted by me in accordance with law; that I examined the police reports

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and testimonies presented; that there is reasonable ground to believe that theoffense charged had been committed and that the accused is probably guiltythereof; that the accused was informed of the complaint and of the evidencesubmitted against him and was given the opportunity to submit controvertingevidence; and that the filing of this information is with prior authority andapproval of the City Prosecutor.


SUBSCRIBED AND SWORN to before me this 23 rd day of January

2010 in the City of Manila.

(sgd) Marc Anthony BalboaCity Prosecutor

Approved:City Prosecutor

WITNESSES:

Lamon Vhong Sevilla, Jr . No. 23 Recto Avenue, ManilaBinggoy Gestrada No. 25 Recto Avenue, Manila

BAIL NOT RECOMMEDED

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Criminal Case No: 123456-versus- For: Estafa

MARIA MERCEDES DEL BARRIO,Accused.

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INFORMATION

The undersigned, provincial prosecutor, upon sworn complaintoriginally filed by the offended party, accuses Maria Mercedes Del Barrio ofthe crime of ESTAFA, committed as follows:

That on or about February 7, 2011, and for a period prior andsubsequent thereto, in the City of Manila, Philippines, within the jurisdictionof this Court, the said accuse, with unfaithfulness or abuse of confidence,and with intent to defraud, did then and there wilfully, unlawfully, and

feloniously, in her capacity as Cash Custodian of the Metrobank, ManilaBranch, take from the Bank's Vault the amount of ONE HUNDRED FIFTYTHOUSAND (P150,000.00) PESOS, which is under her direct custodyand/or accountability, misappropriate and convert to her own personal useand benefit, without the knowledge and consent of the offended party,despite repeated demands for her to account and/or return the said amount,she refused and failed, and still fails and refuses to the damage and prejudiceof the Metrobank, Manila Branch, in the aforementioned amount of ONEHUNDRED FIFTY THOUSAND (P150,000.00) PESOS.

CONTRARY TO LAW


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CERTIFICATE OF PRELIMINARY INVESTIGATION

I hereby certify that a preliminary investigation in this case wasconducted by me in accordance with law; that I examined the police reportsand testimonies presented; that there is reasonable ground to believe that theoffense charged had been committed and that the accused is probably guiltythereof; that the accused was informed of the complaint and of the evidencesubmitted against him and was given the opportunity to submit controvertingevidence; and that the filing of this information is with prior authority andapproval of the City Prosecutor.

(sgd) Roger Pingris

Asst. City Prosecutor

SUBSCRIBED AND SWORN to before me this 21 rd day of February

2011 in the City of Manila.

(sgd) Marc Anthony BalboaCity Prosecutor

Approved:City Prosecutor

WITNESSES:Lamon Vhong Sevilla, Jr . No. 23 Recto Avenue, ManilaBinggoy Strada No. 25 Recto Avenue, Manila

BAIL RECOMMENDED: P_____________________

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Criminal Case No: 123456

-versus- For: Murder

HONESTO BALINGIT,Accused.

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MOTION FOR BAIL

Accused, by his undersigned counsel, respectfully states:

1. That accused is currently detained at the Manila City Jail for the chargeof Murder and has been behind bars since his arrest on August 1, 2013;

2. That no bail has been recommended for his temporary release on theassumption that the evidence of guilt is strong;

3. That the prosecution's evidence of guilt against accused is weak as thereis no direct evidence that will point to the accused to have committed thecharges against him.

4. The records will show that accused was maliciously implicated in thecase through the sworn statements of JOEL BALATBAT and JEROMEMARAMAG who subsequently recanted their testimonies and confessed,among others, that they were made to sign the "affidavits of witnesses"against their will. Copies of the Affidavits of Recantation are hereto

attached as Annexes "A" and "B")

5. That there are no other physical or documentary evidence to show thataccused is guilty of the crime charged;

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6. That the burden of showing that evidence of guilt is strong is on the prosecution, and since this fact is not satisfactorily shown, accused isentitled to bail as a matter of right during the pendency of the criminalcase.

WHEREFORE, upon prior notice and hearing, it is respectfully prayedthat the accused HONESTO BALINGIT be admitted to bail in such amountas this Honorable Court may fix.

City of Manila, July 15, 2010

(sgd) ATTY. MANA N. ANGGOL

Counsel for AccusedUnit 10, Tariff Building, Recto,ManilaIBP No. 123456; 1/10/10 ManilaPTR No. 1234567; 01/10/10 ManilaRoll No. 12345; 5/05/05MCLE No. I 001234; 9/09/09MCLE No. II 005678; 9/09/09

NOTICE OF HEARING

THE BRANCH CLERK OF COURTRegional Trial Court, Branch 1Manila

Greetings!

Please submit the foregoing motion to the Honorable Court on August27, 2013 at 8:30 in the morning for its favorable consideration and approval.

ATTY. MANA N. ANGGOLCounsel for Accused

Copy furnished by personal service:

Prosecutor ROBO T. COPOffice of the City Prosecutor, Manila City

Atty. Andy BarrocaPrivate Prosecutor2233 Recto Avenue, Manila

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Criminal Case No: 123456-versus- For: Rape

JULIUS CESAR GREPO,Accused.

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MOTION TO QUASH

Accused, by his undersigned counsel, respectfully moves to quash theinformation filed against him on the ground that the criminal action orliability against the accused has been extinguished, under par. (g), Sec 3,Rule 117 of The Revised Rules of Court.

ARGUMENTS

1. Accused Julius Cesar Grepo who is the accused in the said criminalinformation for rape, validly married the victim Cleopatra Tamayo on

July 2, 2010 at a church wedding in Quiapo Church, Manila. A copyof the marriage license and marriage certificate of both parties arehereto attached as Annex A and Annex B , respectively.

2. Under the Art. 266-C of the Revised Penal Code, the subsequent validmarriage between the offender and the offended party in the crime ofrape shall extinguish the criminal action or the penalty imposed.

WHEREFORE, it is respectfully prayed that the information filedagainst the accused be dismissed.

City of Manila, July 17, 2010

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(sgd) ATTY. MANA N. ANGGOLCounsel for AccusedUnit 10, Tariff Building, Recto,ManilaIBP No. 123456; 1/10/10 ManilaPTR No. 1234567; 01/10/10 ManilaRoll No. 12345; 5/05/05MCLE No. I 001234; 9/09/09MCLE No. II 005678; 9/09/09

THE BRANCH CLERK OF COURTRegional Trial Court, Branch 1Manila

Greetings!

Please submit the foregoing motion to the Honorable Court on June 25,2010 at 8:30 in the morning for its favorable consideration and approval.

ATTY. MANA N. ANGGOLCounsel for Accused

Copy furnished by personal service:

Prosecutor ROBO T. COPOffice of the City Prosecutor, Manila City

Atty. Andy BarrocaPrivate Prosecutor2233 Recto Avenue, Manila

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