REPUBLIC OF THE PHILIPPINES
METROPOLITAN TRIAL COURT
NATIONAL CAPITAL REGION
PASIG CITY BRANCH
PEOPLE OF THE PHILIPPINES,
Plaintiff,
Crim. Case No.
versus For: Viol. Of BP 22 (9 counts)
Accused.
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URGENT AND EX-PARTE MOTION
(TO SET ASIDE ORDER AND LIFT WARRANT OF ARREST)
with
ENTRY OF APPEARANCE
Accused, by and through the undersigned counsel, to this Honorable
Court, most respectfully avers that:
1. The undersigned counsel submits his entry of appearance as
counsel de parte of accused , hence, it is requested that the undersigned
be furnished with all notices, copies and other processes and pleadings in
this case;
2. On November 20, 2004, a Warrant of Arrest was served upon
the accused, and the same posted bail for his provisional liberty, which had
been granted through an Order of Release1 dated issued by Hon. Judge,
presiding judge of the Regional Trial Court of Marikina City Branch;
1
Annex “1”
3. When this case was set for arraignment on June 17, 2004, the
accused was not able to appear because he did not receive any notice of
arraignment;
4. It was thereafter learned that a bench warrant was issued by this
Honorable Court;
5. It is not the intention of the accused to delay the proceedings of
this case.
PRAYER
WHEREFORE, PREMISES CONSIDERED, in the highest interest
of justice, equity, and fair play, herein accused most respectfully pray of this
Honorable Court that the Order dated be set aside and the warrant of arrest
be lifted accordingly.
Accused further prays for such other measures of relief as are just and
equitable under the premises.
Quezon City for Pasig City.
LAW OFFICE
Counsel for the Accused
For the Firm:
Copy furnished:
PASIG CITY PROSECUTOR OFFICE
Pasig City Hall, Pasig City