Republic of the Philippines

12th Judicial Region

REGIONAL TRIAL COURT
Branch 15
Cotabato City

PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 2016-8487

Plaintiff,

-versus- -for-

ALMORIE BAYAO BRAHIM, VIOLATION OF SECTION

and TONINA MAULANA ALIPULO 12 OF R.A. NO. 9165
Accused.
x-------------------------------------------x

MANIFESTATION AND URGENT MOTION

(FOR MEDICAL EXAMINATION)

ACCUSED ALIPULO, assisted by the Public Attorneys Office for

purposes of this motion only and unto this Honorable Court, most
respectfully avers that:

1. She is currently suffering an infection of the uterus due to the

prolonged use of Intra-Uterine Device (IUD);

2. Her infection could graduate to a more severe case of infection that

could lead to death if not properly medically examined or treated;

3. Accused is praying for compassion and humanitarian consideration

from this Honorable Court to allow her to be immediately brought to a
government hospital for the required medical check-up;

4. This motion is filed solely for the purpose as stated and is not
intended for any other reasons;

PRAYER

WHEREFORE, it is most respectfully and humbly prayed of this

Honorable Court to allow the accused, TONINA MAULANA ALIPULO,
to be brought to the nearest government hospital for the conduct of the
required medical examination.

Other reliefs just and equitable are also prayed for.

April 6, 2017. Cotabato City, Philippines.

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 FOR ACCUSED ALIPULO:

Assisted by:

PUBLIC ATTORNEYS OFFICE - COTABATO CITY DISTRICT

2nd Floor Unilab Building, Sideout Badminton Courts
Sinsuat Avenue, Cotabato City

By:

ATTY. MUAMAR RHYS T. GUIAMADEL

Assisting Counsel
Public Attorney I
Roll of Attorneys No. 59998
IBP No. 930382
MCLE Compliance No. V-0022775

Copy furnished:

CITY PROSECUTION OFFICE

SK Pendatun Avenue
9600 Cotabato City
By:______________________________
Date: ____________________________

NOTICE AND REQUEST

ATTY. LAILANE C. TIBORON-MASTURA

Branch Clerk of Court
Regional Trial Court Branch 15
Cotabato City

CITY PROSECUTION OFFICE

SK Pendatun Avenue
9600 Cotabato City

GREETINGS!

Please be submit the foregoing motion for the immediate consideration

and resolution of this Honorable Court upon receipt thereof without further
oral arguments or appearance of counsel and parties.

ATTY. MUAMAR RHYS T. GUIAMADEL

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