Sunteți pe pagina 1din 3

Republic of the Philippines

Metropolitan Trial Court


National Capital Judicial Region
Caloocan City
Branch 53

People of the Philippines,


Plaintiff,

- versus - Crim. Case Nos. 232321-32


For: Violations of BP 22
Raquel Peralta,
Accused.
x-----------------------------------------x

MOTION TO REVIVE

COMES NOW, Private Complainant, by the undersigned private prosecutor


under the direct control and supervision of the public prosecutor respectfully avers
that:

1. On February 25, 2009, the undersigned private prosecutor received an


order from this Honorable Court dated February 10, 2009 provisionally dismissing
the instant cases with the express conformity of the accused upon motion by the
counsel for the accused invoking the constitutional right of the accused for the
speedy disposition of the cases filed against her.

2. The failure of the private prosecutor to appear on the hearing of the


cases scheduled on February 10, 2009 was not intentional but was due to the fact
that she had suffered from abdominal pain and diarrhea on the said date. Copy of
the duly notarized medical certificate is attached and integrated hereto as Annex
A.

3. Private complainant is very much interested to prosecute the cases


against the accused considering the amount involved in the said cases;

PRAYER

WHEREFORE, in view of the foregoing premises, it is respectfully prayed of


this Honorable Court that the Order dated February 10, 2009 be set aside and the
instant cases against the accused be revived.

1
Other relief and remedies, just and equitable under the premises are likewise
prayed for.

May 18, 2009, Quezon City for the City of Caloocan.

ATTY. ARLENE D. BANOCNOC


Private Prosecutor
2nd Floor SGS Foundation Building
1335 G. Araneta Avenue, Quezon City 1114
PTR No. 1173822/January 6, 2009/Quezon City
IBP No. 767195/January 6, 2009/Manila IV
Roll of Attorneys No. 42680
MCLE Compliance No. II-0001535

With my conformity:

Assistant Prosecutor Oscar T. Yu


Office of the City Prosecutor
Caloocan City

NOTICE OF HEARING

Assistant Prosecutor Oscar T. Yu


Office of the City Prosecutor
Caloocan City

Atty. Jack A. Mendaros


Counsel for the Accused
Public Attorneys Office
Caloocan City

The Branch Clerk of Court


MeTC Branch 53
Caloocan City

Greetings!

Please be informed that the foregoing Motion to Revive shall be submitted for
the consideration and approval of the Honorable Court on May 29, 2009 at 8:30 in
the morning.

Atty. Arlene D. Banocnoc

2
Copy furnished:

Assistant Prosecutor Oscar T. Yu


Office of the City Prosecutor
Caloocan City

Atty. Jack A. Mendaros


Counsel for the Accused
Public Attorneys Office
Caloocan City

Raquel Paralta
Accused
Batangas Street corner
Tomas Mapua Street
Sta Cruz, Manila

EXPLANATION

A copy of this Motion was furnished upon the accused by registered mail with
return card due to lack of personnel to effect personal service.

Atty. Arlene D. Banocnoc