Republic of the Philippines

REGIONAL TRIAL COURT

Third Judicial Region
BRANCH __
___________ City
PEOPLE OF THE PHILIPPINES,
Plaintiff,
-versus___________

CRIM. CASE NO.

___________________,
Accused.
x----------------------------------------x

MOTION TO
SUSPEND ARRAIGNMENT
Accused, __________________, by counsel, alleges
1. That arraignment in the instant suit has been set on
_____________ at 8:30 oclock in the morning;
2. That on _____________, Accused filed a Motion for
Reconsideration vis-a-vis the June 13, 2014
Recommendation/Resolution with the Office of the
City Prosecutor, of which this Honorable Court was
duly furnished with a copy thereof. For easy
reference, however, another copy of the Motion is
hereto attached as Annex A;
3. That the above Motion for Reconsideration has not
been resolved to date;
4. That under Section 11 (c), Rule 117 of the Revised
Rules of Criminal Procedure, arraignment shall be
suspended when a petition for review of the
resolution of the prosecutor is pending at either the
Department of Justice, or the Office of the President.
It is humbly submitted that the pendency of the
aforesaid Motion for Reconsideration is akin to the
situation earlier adverted to;

5. That, despite diligent efforts on the part of

Undersigned Counsel, Accused, who is in South
Korea, has not been informed of the _____________
arraignment; and
6. That a suspension of the arraignment will afford
herein Accused the opportunity to prove that the
present suit should not have been filed in the first
place.

PRAYER
WHEREFORE, in the highest interests of substantial
justice, it is most respectfully prayed that the arraignment in
the present case be suspended.
_____________ for _____________ City, _____________.

ATTY. _____________
Counsel for Accused _____________

The Branch Clerk of Court

Regional Trial Court
BRANCH _
_____________ City
GREETINGS:
Kindly submit the foregoing Motion to the Honorable
Court immediately upon receipt thereof for its consideration
and favorable resolution.
_____________
COPY FURNISHED:
Office of the City Prosecutor
Hall of Justice
Angeles City

EXPLANATION
Pursuant to Sec. 11, Rule 13, in relation to Sec. 3, Rule
1, 1997 Rules of Civil Procedure, it is hereby explained that
the filing of the above Motion with this Honorable Court and
its services upon the other parties were done by registered
mail/licensed courier service and not personally, the
preferred mode, due to the distances involved.

ATTY. _____________