Republic of the Philippines

REGIONAL TRIAL COURT

9th Judicial Region
Branch __, Zamboanga City

PEOPLE OF THE PHILIPPINES NPS DOCKET NO. xxx

Plaintiff,
- versus- -for-
xxx Violation of Sec. 5 & 11 Art. II of
R.A. No. 9165
Accused,
x-----------------------x

MOTION TO BRING ACCUSED

TO A GOVERNMENT HOSPITAL
FOR MEDICAL TREATMENT

COMES NOW, herein Accused xxx, through the undersigned

counsel, unto this Honorable Court, most respectfully submits this Motion to
Bring Accused to a Government Hospital for Medical treatment, and hereby
deposes and says that:

1. Herein Accused is now detained at the Zamboanga City Jail, for

the alleged violation of the above-mentioned provisions of law;

2. Meanwhile, in his present detention, herein Accused is

complaining of stomachache due to Loose Bowel Movement
(LBM) for (2) weeks already and loss of appetite and body
weakness;

3. On the basis of the foregoing findings, it is recommended that

inmate xxx should undergo further medical examination at
Zamboanga City Medical Center to determine his real health
status for proper medical evaluation and treatment, as
evidenced by a copy of Certification attached herewith as
Annex A;

WHEREFORE, premises considered, herein Accused, through

undersigned collaborating counsel, most respectfully pray to this Honorable
Court that the accused be brought to the Zamboanga City Medical Center for
medical treatment, and in the same Order, directing the jail warden to
provide the necessary escorts for the said purpose, and for whatever is just
and legal under the said premises.

Zamboanga City, Philippines, _____, 2017.

 ATTY. xxx
Counsel for the Accused
Zamboanga City
P.T.R. No. ________
I.B.P. No. _________
Roll of Attorney No. _________
M.C.L.E. Compliance No. _____________

NOTICE OF HEARING

The Branch Clerk of Court

RTC, Branch__
Zamboanga City

Greetings:

Please submit the foregoing motion for consideration and approval of

the Honorable Court immediately upon receipt hereof, and without further
oral argument.

xxx

The City Prosecutors Office

Hall of Justice
Zamboanga City

G r e e t i n g s:

Please take notice that the foregoing motion is being submitted for the
consideration and approval of the Honorable Court immediately upon receipt
hereof, and without further oral argument.

xxx