Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch _____, Pasay City

PEOPLE OF THE PHILIPPINES

Criminal Case No.
_______________________
- versus– For: __________________
UNDER ARTICLE 315,
____________________, PARAGRAPH 2(A)
Indian National, OFTHE REVISED
Accused, PENAL CODE
x------------------------------------------x

URGENT EX-PARTE MOTION FOR THE ISSUANCE OF HOLD

DEPARTURE ORDER AND ISSUANCE OF WARRANT OF ARREST OF
______________(NAME)________

COMES NOW, the Private Complainant, by the undersigned public

prosecutor and unto this Honorable Court, respectfully moves for the
issuance of the Hold Departure Order (HDO) and warrant of arrest
against the accused, and alleges that:

1) The Accused is _____________________________as indicated in the

photocopy of his passport;

2) The Accused __________________is an Indian National and is a

businessman by profession and notoriously known as the owner of
________________________ Group;

3) That ____________________ jumped bail in another case in RTC Branch

______with Docket No.___________________________________;
4) A copy of ___________________ passport indicating his correct name and
nationality is herewith attached as Annex “A”.

5) Due to the access of the Accused to flights, the Private Complainant is

left with no other remedy but to pray of this Honourable Court to issue
the Hold Departure Order and Arrest Warrant against the accused
________________________________.

6) The Private Complainant further prays of this Honorable Court to

issue a Warrant of Arrest against _________________since he failed to
submit himself to this Honorable Court’s jurisdiction by not attending
the pre-trial of this case which is a violation of his duty to inform the
court of his whereabouts pending the criminal case against him1.

WHEREFORE, premises considered, it is respectfully prayed of this

Honorable Court that:
1) _______________, Indian National be held under a HOLD DEPARTURE
ORDER; and
2) that a Warrant of Arrest be immediately issued against him for his
immediate arrest so as not to frustrate the wheels of justice.

Pasay City, ___ December 2017.

1
Silverio vs. Court of Appeals