Republic of the Philippines

REGIONAL TRIAL COURT

Tenth Judicial Region
BRANCH 10
Malaybalay City, Bukidnon

PEOPLE OF THE PHILIPPINES

-versus- CRIM. CASE No. 66434-17

For: Violation of Republic Act No.
9165

CARLOS LUCERO,
Accused.
x------------------------------------x

MOTION FOR LEAVE OF COURT TO FILE DEMURRER TO EVIDENCE

THE ACCUSED, CARLOS LUCERO, through counsel unto this Honorable

Court, most respectfully state that:

1. That the prosecution has presented its witnesses and has formally
offered its evidence;

2. That the accused seeks leave of court to file a Demurrer to

Evidence, on the ground that the evidence presented by the
prosecution is not sufficient to warrant a conviction of the guilt of
the accused beyond reasonable doubt;

3. That this motion is filed in good faith and not for the purpose of
delaying the proceedings of this case;

PRAYER

WHEREFORE, it is respectfully prayed that the accused be granted that

the instant motion for Leave of Court to File a Demurrer to Evidence.

Relief and other remedies equitable, just, and proper in the premises are
likewise prayed for.

March 16, 2017, Malaybalay City, Bukidnon

RAFFY J. RONCALES
Counsel for the Accused
Malaybalay City, Bukidnon
Tel. No. [03] 756-868/ Mobile Phone No. [0917] 3287-167
IBP Receipt No. 0285688, Jan. 5, 2017, Bukidnon Chapter
PTR No. 8821, Jan. 5, 2017, Malaybalay City, Bukidnon
Roll No. 52421 [April 2016]
MCLE V Certificate No. 000562 [March 5, 2016]
 NOTICE

THE BRANCH CLERK OF COURT THE CITY PROSECUTOR

Regional Trial Court, Branch 10 Malaybalay City, Bukidnon
Malaybalay City, Bukidnon

GREETINGS:

PLEASE TAKE NOTICE that the undersigned counsel for the accused will submit the
foregoing Motion for Leave of Court to File Demurrer to Evidence for the consideration of the
Honorable Court immediately upon receipt without further arguments.

RAFFY J. RONCALES

COPY FURNISHED: the City Prosecutor, Malaybalay City, Bukidnon