Republic of the Philippines

First Judicial Region

MUNICIPAL TRIAL COURT
Sta. Barbara, Pangasinan

THE PEOPLE OF THE PHILIPPINES,

Plaintiff,

CRIMINAL CASE NO. 4626

- versus - For: Violation of Art. 202
(Vagrancy)

REYMABELLE MORANTE y Maldo,

MARIA PATRICIA RIZZA CASTILLO
y Villarama, KATE MECINA y
MADRIGAL,
Accused.
x ---------------------------------- x

MOTION TO REVIVE
with MOTION TO DISMISS

ACCUSED REYMABELLE MORANTE, represented by the PUBLIC

ATTORNEYS OFFICE, through the undersigned counsel, respectfully states
that:

1. Accused is one of the accused in the above-mentioned case.

2. On 12 July 2005, an Order was issued sending the case to the

Archived Files because the accused could not be located at her given address.

3. However, the accused was unaware of the case they filed against
her.

4. While the case was pending, Republic Act (RA) No. 10158 was
enacted decriminalizing Vagrancy, amending Article 202 of the Revised
Penal Code.

5. Section 2 of RA No. 10158 states that All pending cases under the
provisions of Article 202 of the Revised Penal Code on Vagrancy prior to its
amendment by this Act shall be dismissed upon the effectivity of the Act.

WHEREFORE, accused respectfully prays for the revival of the above-

mentioned case; and thereafter dismiss the case as Vagrancy was
decriminalized under RA No. 10158.

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 Other just and equitable reliefs are also prayed for.

City of Dagupan; 24 July 2017.

PUBLIC ATTORNEYS OFFICE

Department of Justice
Counsel for the Accused
Justice Hall, Bonuan Tondaligan
Dagupan City
By:

CRESENCIO D. DELA CRUZ, JR.

Public Attorney II
Roll of Attorneys No. 59619
IBP Life Member Roll No. 012426
MCLE Compliance No. V 0006537 March 2, 2015

REQUEST FOR & NOTICE OF HEARING

THE BRANCH CLERK OF COURT

Municipal Trial Court
Sta. Barbara, Pangasinan

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 Tuesday, 1 August 2017 at 1:30 in the
afternoon.

COUNSEL

PROS. CATHERINE S. CARAGAN

Assistant Provincial Prosecutor
OFFICE OF THE PROVINCIAL PROSECUTOR
Dagupan City

Please take notice that counsel has requested to be heard on Tuesday,

1 August 2017 at 1:30 in the afternoon.

COUNSEL

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