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Carnapping LANTICSE

The document is an offer by the accused, Reymart Sarona Lanticse, to plead guilty to the lesser offense of simple theft rather than the original charge of carnapping. The accused was charged with carnapping for an incident on January 31, 2019 in Sarangani Province. If allowed to change the plea to simple theft, the accused requests that the penalty imposed be within the range of 6 months and 1 day to 2 years and 4 months in prison, taking into account the circumstances of the guilty plea and extreme poverty and necessity. A hearing on the offer is scheduled for May 31, 2019.

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Han Nah
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60 views4 pages

Carnapping LANTICSE

The document is an offer by the accused, Reymart Sarona Lanticse, to plead guilty to the lesser offense of simple theft rather than the original charge of carnapping. The accused was charged with carnapping for an incident on January 31, 2019 in Sarangani Province. If allowed to change the plea to simple theft, the accused requests that the penalty imposed be within the range of 6 months and 1 day to 2 years and 4 months in prison, taking into account the circumstances of the guilty plea and extreme poverty and necessity. A hearing on the offer is scheduled for May 31, 2019.

Uploaded by

Han Nah
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 4

Republic of the Philippines

SUPREME COURT
REGIONAL TRIAL COURT
11th Judicial Region
JUSTICE ON WHEELS
Sarangani Province

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. 01113-


Plaintiff, 19

-versus- -for-

REYMART SARONA LANTICSE CARNAPPING (1st paragraph


Alias BAGTIK, in rel. to 1st phrase of the 2nd
Accused. paragraph of Sec. 3 of RA
X------------------------------------------X 10883, as amended)

OFFER TO PLEAD GUILTY TO A LESSER OFFENSE

ACCUSED, through counsel from the Public Attorney’s Office,


and to this Honorable Court respectfully states, that;

Accused stands charged for alleged Carnapping that took place


on 31 January 2019 at SOCOTECO II Compound, Barangay Malalag,
Municipality of Malungon, Sarangani Province;

Pursuant to provisions on plea bargaining, the accused hereby


withdraws her plea of not guilty and offers to enter a plea to the lesser
offense of SIMPLE THEFT under Art. 308 of the Revised Penal Code,
which is necessarily included in Carnapping, the offense charged
under Criminal Case No. 01113-19 with admission of the facts
constituting the lesser offense, but not the offense charged;

Page 1 of 4
That Accused also prays that the circumstance of plea of guilt
and extreme poverty and necessity be appreciated in his favor in the
imposition of the penalty;

Thus, in People vs. Macbul, G.R. No. L-48976, October 11, 1943,
the trial court considered extreme poverty and necessity as a
mitigating circumstance falling within Article 13 par. 10 of the Revised
Penal Code, which authorizes the court to consider in favor of an
accused "any other circumstance of a similar nature and analogous to those
above mentioned”.

Accused respectfully and humbly prays that should his offer be


given due course, the penalty imposed upon him is within the range
of prision correccional, minimum period or from 6 months and 1 day
to 2 years and 4 months;

WHEREFORE, it is most respectfully prayed that the offer to


plead guilty to a lesser offense be given due course and that the penalty
to be imposed upon the accused is within the range of prision
correccional, minimum period or from 6 months and 1 day to 2 years
and 4 months.

Alabel, Sarangani Province, 08 May 2019.

RESPECTFULLY SUBMITTED:

CONFORME:

REYMART SARONA LANTICSE

By:

PUBLIC ATTORNEY’S OFFICE


Department of Justice

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Sarangani District Office
Alabel, Sarangani Province

BY:

BAI ALEFHA HANNAH M. MUSA-ABUBACAR


Public Attorney I
Roll of Attorney No. 67366
MCLE Compliance No. VI-0009755
IBP OR No. 098228/01-January-2019
Email Add: hannahalefha20@gmail.com
09090154295
PTR Exempt

Noted by:

SALVADOR G. TALAMAYAN
OIC-District Public Attorney

NOTICE

ATTY. CANDICE T. PELARION


The Clerk of Court
Branch 50
Alabel, Sarangani Province

G r e e t i n g s:

Please submit immediately the foregoing Motion for the


consideration and approval of the Honorable Court and set for hearing
on 31 May 2019 at 2:00 o’clock in the afternoon.

BAI ALEFHA HANNAH M. MUSA-ABUBACAR

Page 3 of 4
Provincial Prosecutor’s Office
Alabel, Sarangani Province

Please take notice that the foregoing Motion will be submitted


on 31 May 2019 at 2:00 o’clock in the afternoon for the consideration
and approval of the Honorable Court.

BAI ALEFHA HANNAH M. MUSA-ABUBACAR

CC: Office of the Provincial Prosecutor

Page 4 of 4

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