Republic of the PhilippinesREGIONAL TRIAL COURT5th Judicial RegionBranch 61, Iriga City

PEOPLE OF THE PHILIPPINES, Complainant,

-versus- CRIM.CASE NO. 567498 For: HOMICIDE

LESTER LLOYD D. VALENZUELA, Accused.

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URGENT MOTION TO SUSPEND ARRAIGNMENT AND SUBMIT ACCUSED FOR MENTAL AND PSYCHIATRIC EXAMINATION

COMES NOW, the Accused, by and through the undersigned Counsel, unto this Honorable Court, most respectfully move for the suspension of the arraignment and submission of the accused for mental and psychiatric examination, and avers:

1. That the accused could not properly and intelligently enter a plea because he is suffering from a mental illness;

2. That Counsel for the accused believes that the latter may be incompetent to stand trial, and may have been insane at the time the alleged offense was committed; and

3. That before the commission of the crime, the herein accused was confined for two (2) occasions at the psychiatric ward of the Bicol Medical Center, Department of Psychiatry, Cadlan, Pili, Camarines Sur. A copy of the Medical Certificate is attached as Annex 1 and made an integral part hereof.

PRAYERWHEREFORE, it is respectfully prayed that the Honorable Court issue an order, pursuant to Section 11(a), Rule 116 of the Revised Rules of Criminal Procedure, for the suspension of the arraignment of the herein accused and the same be confined at the Bicol Medical Center, Department of Psychiatry, Cadlan, Pili, Camarines Sur.

Other reliefs, just and equitable, are likewise prayed for.

Iriga City, Philippines, February 10, 2015.

ATTY. MONA LIZA C. NOVELACounsel for the AccusedNOVELA & BARROGA LAW FIRM2/F Tansylit Bldg., San Roque, Iriga CityPTR No. 2345678, Jan. 2, 2015, Iriga CityRoll No. 33445IBP Lifetime No. 456789MCLE Compliance IV-0005776

REQUEST FOR AND NOTICE OF HEARING

THE BRANCH CLERK OF COURTRegional Trial CourtBranch 61, Iriga City

Greetings!

Please submit the foregoing Motion to the Court for its consideration and approval immediately upon receipt hereof and kindly include the same in the courts calendar for hearing on February 13, 2015 at 8:30 in the morning.

ATTY. TRISTAN JORDAN MARGATEAssistant City ProsecutorHall of Justice, San Isidro, Iriga CityGreetings! Please take notice that the foregoing Motion shall be submitted for the consideration and approval of the Honorable Court on Friday, February13, 2015 at 8:30 in the morning or as soon as counsel and matter may be heard.

ATTY. MONA LIZA C. NOVELACounsel for the AccusedNOVELA & BARROGA LAW FIRM2/F Tansylit Bldg., San Roque, Iriga CityPTR No. 2345678, Jan. 2, 2015, Iriga CityRoll No. 33445IBP Lifetime No. 456789MCLE Compliance IV-0005776

Copy Furnished through Personal Service:

ATTY. TRISTAN JORDAN MARGATEAssistant City ProsecutorHall of Justice, San Isidro, Iriga CityDate received: _________________Signature:_____________________

MS. JANNIE JILL B. CALLOSPrivate ComplainantSalvacion, Iriga CityDate received: _________________Signature:_____________________