Scribd
Upload
103 views2 pages

Comment and Motions

The document discusses motions filed in a criminal case against Gina Tan y Reyes for reckless imprudence resulting in serious physical injuries. A motion is made for judicial determination of probable cause and to dismiss the case. It is argued that the evidence against the accused is unbelievable and incredible. A counter-affidavit and motion to dismiss is also filed, arguing that the accused did not commit the crime and there is an absence of probable cause. The condition of the road where the incident occurred is also discussed.

Uploaded by

Glaiza Cel
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
103 views2 pages

Comment and Motions

The document discusses motions filed in a criminal case against Gina Tan y Reyes for reckless imprudence resulting in serious physical injuries. A motion is made for judicial determination of probable cause and to dismiss the case. It is argued that the evidence against the accused is unbelievable and incredible. A counter-affidavit and motion to dismiss is also filed, arguing that the accused did not commit the crime and there is an absence of probable cause. The condition of the road where the incident occurred is also discussed.

Uploaded by

Glaiza Cel
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/ 2

Comment and Motions

Resetting todays arraignment and pre-trial by


the Court Social Worker.
Pp v Gina Tan y Reyes

July 26, 2018


Comment or Opposition (counsel for the
accused)

Re : Reckless Imprudence resulting in Serious


Physical Injuries.

X no crime.

X full blown trial.

/ dismissed right away.

/ victim was the victim of a motor accident


years ago.

Comment

Motion for Judicial Determination of Probable


Cause with Motion to Dismiss

(City Prosecutor)

Evidence by the complainant during the


preliminary investigation - unbelievable or
utterly incredible.

MOTION FOR REINVESTIGATION WITH ENTRY


OF APPEARANCE
X be dismissed because it needs submission and
appreciation of evidence. And only through full
blown trial.
> page 188

> all copies of orders, notices etc re the above


: must proceed to trial on merits. case be snet to the undersigned whose office
address I written below his name written below

Reason : this case is filed by the Prosecutors


? Constancia? Office without giving the accused a chance to
file a motion for reconsideration or petition for > the complaint lack probable cause according
review to the National Prosecutions Office or to to the defendant. It should be dismissed.
the Secretary of Justice.

> cannot travel more than the speed mentioned


> Motion for Reinvestigation in the case because of the deplorable condition
of the road, rugged, with pootholes and gravel
> Counsel of the accused
paved.

Manifestation and Motion


> the complainant only slipped and fell.

> Accused filed a Petition for Review to the Sec


> witnessed by several bystanders..she was only
of DOJ. (wait for the SEC of DOJ for the
scraped by long and pointy stones the reason
Petition.)
she suggested mefenamic.

MOTION FOR JUDICIAL DETERMINATION OF


> the medical certificate reveals that the victim
PROBABLE CAUSE WITH MOTION TO DISMISS
is an inborn pilay.

> accused has not been arraigned on the


charge.

> consistent stand of the accused that she never


committed the crime. > accused mentioned SEc 412 of the Road
Government Code of 1991. RA7160
: absence of probable cause and for the
consequent dismissal

: investigating prosecutor nonetheless


indicted her of the crime charged.
CRIM CASE no. Q-17-07827

Legal basis for the motion:


Reset Arraignment/Pre-trial

Rule 112, Section 5 (a) RR of criminal procedure.

Stated injury :

Fracture Closed complete displaced transverse


tibia-fibula, left

Counter-Affidavit with Motion to Dismiss

You might also like