Republic of the Philippines

REGIONAL TRIAL COURT

5th Judicial Region
Branch 61, Iriga City

PEOPLE OF THE PHILIPPINES,

Complainant,
-versus-

CRIM.CASE NO. 567498

For: HOMICIDE

LESTER LLOYD D. VALENZUELA,

Accused.
x----------------------------------------------x
URGENT MOTION TO SUSPEND ARRAIGNMENT AND SUBMIT
ACCUSED FOR MENTAL AND PSYCHIATRIC EXAMINATION
COMES NOW, the Accused, by and through the undersigned
Counsel, unto this Honorable Court, most respectfully move for the
suspension of the arraignment and submission of the accused for mental and
psychiatric examination, and avers:
1. That the accused could not properly and intelligently enter a plea
because he is suffering from a mental illness;
2.

That Counsel for the accused believes that the latter may be
incompetent to stand trial, and may have been insane at the time
the alleged offense was committed; and

3. That before the commission of the crime, the herein accused was
confined for two (2) occasions at the psychiatric ward of the Bicol
Medical Center, Department of Psychiatry, Cadlan, Pili, Camarines
Sur. A copy of the Medical Certificate is attached as Annex 1
and made an integral part hereof.

PRAYER

WHEREFORE, it is respectfully prayed that the Honorable Court

issue an order, pursuant to Section 11(a), Rule 116 of the Revised Rules of
Criminal Procedure, for the suspension of the arraignment of the herein
accused and the same be confined at the Bicol Medical Center, Department
of Psychiatry, Cadlan, Pili, Camarines Sur.
Other reliefs, just and equitable, are likewise prayed for.
Iriga City, Philippines, February 10, 2015.

ATTY. MONA LIZA C. NOVELA

Counsel for the Accused
NOVELA & BARROGA LAW FIRM
2/F Tansylit Bldg., San Roque, Iriga City
PTR No. 2345678, Jan. 2, 2015, Iriga City
Roll No. 33445
IBP Lifetime No. 456789
MCLE Compliance IV-0005776

REQUEST FOR AND NOTICE OF HEARING

THE BRANCH CLERK OF COURT

Regional Trial Court

Branch 61, Iriga City

Greetings!
Please submit the foregoing Motion to the Court for its consideration
and approval immediately upon receipt hereof and kindly include the same
in the courts calendar for hearing on February 13, 2015 at 8:30 in the
morning.
ATTY. TRISTAN JORDAN MARGATE
Assistant City Prosecutor
Hall of Justice, San Isidro, Iriga City
Greetings!
Please take notice that the foregoing Motion shall be submitted for the
consideration and approval of the Honorable Court on Friday, February13,
2015 at 8:30 in the morning or as soon as counsel and matter may be heard.

ATTY. MONA LIZA C. NOVELA

Counsel for the Accused
NOVELA & BARROGA LAW FIRM
2/F Tansylit Bldg., San Roque, Iriga City
PTR No. 2345678, Jan. 2, 2015, Iriga City
Roll No. 33445
IBP Lifetime No. 456789
MCLE Compliance IV-0005776
Copy Furnished through Personal Service:

ATTY. TRISTAN JORDAN MARGATE

Assistant City Prosecutor
Hall of Justice, San Isidro, Iriga City
Date received: _________________
Signature:_____________________

MS. JANNIE JILL B. CALLOS

Private Complainant
Salvacion, Iriga City

Date received: _________________

Signature:_____________________