Republic of the Philippines

REGIONAL TRIAL COURT

Second Judicial Region
Branch 14
Lagawe, Ifugao

PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 2475

Plaintiff, For:

-versus- RECKLESS IMPRUDENCE

RESULTING IN SLIGHT
JEFFREY WILSON B. GANO PHYSICAL INJURY IN
Accused. RELATION TO RA 7610
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MOTION

WITH UTMOST RESPECT, the accused, through undersigned

counsel, most respectfully submits this motion and hereby states
that:

1. The accused was charged with attempted reckless

imprudence resulting in slight physical injuries in
relation to RA 7610 and is presently detained at the
BJMP District Jail at Tiger Hill, Baguinge, Kiangan,
Ifugao;
2. The family of the accused intends to perform a native
ritual for the physical and mental well being of the
accused called ‘pahang’ which requires the presence
of the accused at their house;

PRAYER

WHEREFORE, accused through undersigned counsel

respectfully prays of this Honorable Court to allow accused to be at
their house at Ingguiling, Lagawe, Ifugao on July 1, 2017 at 8:00
o’clock in the morning until 3:00 o’clock in the afternoon for the
performance of said ritual.

Other reliefs just and equitable are likewise prayed for.

Respectfully submitted this 30th day of June 2017 at Lagawe,

Ifugao, Philippines.

PUBLIC ATTORNEY’S OFFICE

Department of Justice
By:
 ATTY. DENNIS B. DIMALNAT
Public Attorney II

THE CLERK OF COURT

REGIONAL TRIAL COURT
Branch 14
Lagawe, Ifugao

GREETINGS:

Please submit the foregoing motion for the kind consideration

of the Honorable Court immediately upon receipt hereof.

ATTY. DENNIS B. DIMALNAT

Copy Furnished:

Hilario Ronson H. Tilan

Deputy Provincial Prosecutor
Office of the Provincial Prosecutor
Lagawe, Ifugao