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Republic of the Philippines

REGIONAL TRIAL COURT


6th Judicial Region
-o0o-
PEOPLE OF THE PHILIPPINES,
Complainant,
Criminal Case No.
-versus-

JOEMEL BALIGUAS, ET. AL.,


Accused.
X-----------------------X

MOTION TO ALLOW ACCUSED


TO ATTEND INTERMENT

COMES NOW, accused REYMARK GADUYON Y VILLANUEVA


, through the undersigned Public Attorney, unto this Honorable Court,
most respectfully states:

That accused is a detention prisoner at BJMP Handumanan District


Jail, Brgy. Handumanan, Bacolod City, Negros Occidental;

That his grandfather, the late Norberto Patricio Villanueva, died on


May 14, 2018 and is scheduled to be interred on May 20, 2018, at the
Burgos Cemetery, Bacolod City, after the 2:00 o’clock in the afternoon
mass to beheld at the Our Lady of Lourdes Church, Brgy. Granada,
Bacolod City, machine copy of his Provisional Death Certificate is hereto
attached as Annex “A”;

That in the interest of compassion in line with Filipino tradition,


accused Reymark Gaduyon y Villanueva, hereby seeks permission from
the Honorable Court that he be allowed to pay his last respects and
attend the burial scheduled on the aforementioned date and time duly
escorted by members of the BJMP Handumanan District Jail, Brgy.
Handumanan, Bacolod City, Negros Occidental;
WHEREFORE, it is most respectfully prayed that an order be
issued permitting or allowing accused Reymark Gaduyon y Villanueva to
attend the burial of his grandfather at the Burgos Cemetery, Bacolod
City, on Sunday, May 20, 2018, duly escorted by members of the BJMP
Handumanan District Jail,

RESPECTFULLY SUBMITTED.
Bacolod City, Philippines, May 18, 2018.

PUBLIC ATTORNEY’S OFFICE


Department of Justice
rd
3 Floor, Hall of Justice Bldg.,
Bacolod City, Negros Occidental
(Counsel for the Movant)

By:

IMEE CONN A. DIAMANTE-BUNTALIDAD


Public Attorney II
Roll No. 60133
IBP Lifetime No. 010945
MCLE Compliance No. VI – 0002371

The Clerk of Court


RTC- Branch 43
Bacolod City

Greetings:

Please submit the foregoing motion to the Honorable Court


immediately upon receipt hereof for its consideration and approval.

Thank you!

IMEE CONN A. DIAMANTE-BUNTALIDAD

Copy Furnished to by personal service:

DCPA EMMANUEL LOPE P. LUPISAN


City Prosecutor’s Office
3rd Floor, Hall of Justice Bldg.,
Bacolod City, Negros Occidental