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Appearance As Counsel With Motion To Resolve Petition For Bail and Motion To Set The Hearing Earlier Preferably On December 3, 2012

This document is a motion filed by defense counsel Luciano Cameros on behalf of accused Rey Molejon in criminal cases for murder and frustrated murder. The motion asks the court to (1) acknowledge Cameros as the defense counsel, (2) resolve a pending bail petition for Molejon, and (3) set an earlier hearing date of December 3rd instead of the currently scheduled February 7th due to Molejon being in preventive imprisonment. The motion provides arguments for each request and prays that the court grant the relief sought.

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CHARLOTTE GALLEGO
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106 views4 pages

Appearance As Counsel With Motion To Resolve Petition For Bail and Motion To Set The Hearing Earlier Preferably On December 3, 2012

This document is a motion filed by defense counsel Luciano Cameros on behalf of accused Rey Molejon in criminal cases for murder and frustrated murder. The motion asks the court to (1) acknowledge Cameros as the defense counsel, (2) resolve a pending bail petition for Molejon, and (3) set an earlier hearing date of December 3rd instead of the currently scheduled February 7th due to Molejon being in preventive imprisonment. The motion provides arguments for each request and prays that the court grant the relief sought.

Uploaded by

CHARLOTTE GALLEGO
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
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Republic of the Philippines

REGIONAL TRIAL COURT


11th Judicial Region
BRANCH 18
Digos City, Davao del Sur

PEOPLE OF THE PHILIPPINES, CRIM. CASE NOS. 06 (02) &


Plaintiff, 07 (02)

- versus - FOR:MURDER & FRUSTRATED


MURDER

REY MOLEJON,
Accused.
X - - - - - - - - - - - - - - - - -- - -- - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - /

APPEARANCE AS COUNSEL WITH MOTION TO RESOLVE


PETITION FOR BAIL AND MOTION TO SET THE HEARING
EARLIER PREFERABLY ON DECEMBER 3, 2012

Comes now the ACCUSED, through the undersigned counsel and unto this
Honorable Court, most respectfully avers:

ARGUMENTS

1. Appearance as Counsel for the Accused

That the legal services of the undersigned was engaged by the herein accused
relative to this case;

That the undersigned Counsel enters his appearance as counsel for the accused
in this case. Thus, he prays that he be serve with all notices, writs and orders from this
Honorable court at his given address below;

2. Motion to Resolve Petition for Bail

That accused REY MOLEJON is under detention;

That he filed a Petition for Bail before this Honorable Court asking for his
temporary liberty pending the resolution of this case;

That until now, the said petition for bail was not yet acted upon by this Honorable
Court;
Page 2…./
Motion…/
x----------------/

That the evidence of the prosecution to prove the guilt of the accused is not
strong. Thus, the herein accused is entitled to bail as a matter of discretion;

3. MOTION TO SET THE CASE TO AN EARLIER DATE

That an Order dated November 8, 2012 was issued by this Honorable Court
setting the hearing of this case on February 7, 2013 at 8:30 in the morning;

That the undersigned counsel moves for the resetting of the scheduled hearing of
the above entitled case to an earlier date preferably on December 3, 2012 for the
reason that the scheduled date set by this Honorable Court on February 7, 2012 is yet
very far considering that the herein accused is under preventive imprisonment;

PRAYER

WHEREFORE, in view of the foregoing, ACCUSED, through the undersigned


counsel and unto this Honorable Court, most respectfully prays that his appearance be
entered on record and that his pending resolution for bail be immediately resolve.
Accused further prays that the hearing of this case be set to an earlier date preferably
on December 3, 2012.

Any other just and equitable reliefs available in the premises are likewise prayed
for;

Digos City, Philippines, this 22nd day of November, 2012.


ATTY. LUCIANO G. CAMEROS, CPA
Counsel for the Accused
MCLE Compliance Cert. No. III, 0011279, Aug. 21, 2008
MCLE Compliance Cert. No. IV, 0000673, Nov. 4, 2010
PTR No. 3525808/01-03-2011/Hagonoy, Davao del Sur
IBP O.R.No. 723578/ 12-01-2010/ Digos City
TIN No. 143-089-251/ Roll No. 41499
Corner Magsaysay & Lapulapu Sts. Digos City
Telephone/Fax No. (082)-553-5885
Cellular Phone No. 0910-973-6588
Email address- atty_cameros @yahoo.com

NOTICE

The Clerk of Court


RTC-Branch 18
Digos City, Davao del Sur

Atty. Randolf C. Pensoy


PAO, Digos City
Page three…./
Motion…./
Abellera, et al. vs. Abellera, et. al…./
x----------------------------------------------------/

Sir/Madam:

Please submit the foregoing motion for the kind consideration and approval of
this Honorable Court immediately upon receipt hereof without further arguments from
counsel.

ATTY. LUCIANO G. CAMEROS, CPA

Copy furnished:

Atty. Randolf C. Pensoy


PAO, Digos City

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