Sales, Romeo Solomon Jr.

A
LF

Republic Of The Philippines

REGIONAL TRIAL COURT
Branch 77
QUEZON CITY

PEOPLE OF THE PHILIPPINES CRIMINAL CASE NO. 12345

Plaintiff,

FOR: LIBEL
-versus-

Dr. Alicia Santos

Accused,
X-------------------------------------------------------------------------------------X

URGENT MOTION TO SUSPEND ARRAIGNMENT AND SUBMIT

ACCUSED FOR MENTAL AND PSYCHIATRIC EXAMINATION

COMES NOW, the accused, through the undersigned Counsel, unto this
Court, most respectfully move fo the suspension of the arraignment and
submission of the accused for mental and psychiatric eamination, and
avers:
1. That the accused could not properly and intelligently enters a plea
because he is suffering from a mental illness;

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

3. That before the commission of the crime, the accused was confined
for 2 occasions at the psychiatric ward of Quezon City Medical
Center. 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 accused and the same be confined in the Quezon City Medical
Center in Quezon City

Other releifs, just and equitable, are likewise prayed for.

Quezon City, Philippines, February 12, 2016.

Sales, Romeo Solomon Jr. A
LF

ATTY. ROMEO A. SALES

Counsel for the accused
2nd floor Data Bldg.
Data St. Don Manuel, Quezon City
IBP No. 234534 Jan 27, 2012
PTR No.234532 Jan 27, 2012
Attorneys Roll No. 20123

REQUEST FOR AND NOTICE OF HEARING

THE BRANCH CLERK OF COURT

Regional trial Court

Branch 77, Quezon City

Greetings!

Please submit the foregoing Motion to the ourt for its

consideration and approval immediately upon receipt hereof and
kindly include the same in the Courts calendar for hearing on
February 18, 2016 at 8.30 in the morning.

ATTY. OLIVER G. QUEEN

Assistant City Prosecutor
Hall of justice, Quezon City

Greetings!

Please thak notice that the foregoing Motion shall be submitterd for
the consideration and approval of the Honorable Court on February
18, 2016 at 8.30 in the morning or as sson as counsel and matter may
be heard.

ATTY. ROMEO A. SALES

Counsel for the accused
2nd floor Data Bldg.
Data St. Don Manuel, Quezon City
IBP No. 234534 Jan 27, 2012
PTR No.234532 Jan 27, 2012
Attorneys Roll No. 20123

Copy furnished through Personal Service:

ATTY. OLIVER G. QUEEN

Assistant City Prosecutor
Hall of justice, Quezon City
Sales, Romeo Solomon Jr. A
LF

Date received:___________
Signature:_______________

Ms. KARA B. ZOR-EL

Private Complaint
Quezon City, Philippines