REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 5
LEMERY, BATANGAS

PEOPLE OF THE PHILIPPINES

Plaintiff, CRIM. CASE NO. 375-2016
and
376-2016
-versus-

REYNALDO PUNZALAN y ABUL @

“LANDO”,
Accused.
X---------------------------------------------------X

MANIFESTATION AND MOTION TO SET

FOR PLEA BARGAINING

COMES NOW ACCUSED, through counsel in the above-

entitled case, and to this Honorable Court, most respectfully
avers that:

1. That the Supreme Court enunciated in the case of

Estipona Jr. vs. Lobrigo and People that plea bargaining
is allowed in the cases for violation of R.A. 91651 ;

2. As stated in the same case, “plea bargaining is to be

encouraged because the chief virtues of the system –
speed, economy, and finality – can benefit the accused,
the offended party, the prosecution, and the court”2 ;

3. The accused would like to avail of the said plea

bargaining and is willing to enter a plea of guilty for a
lesser offense in accordance with A.M. No. 18-03-16-SC;

4. For such purpose, the accused moves to submit and

make himself available before this Honorable Court
where his presence is indispensable on 26 June 2018 at
8:30 o’clock in the morning;

1 Estipona Jr. vs. Lobrigo, G.R. No. 226679, August 15, 2017.
2 Ibid.
Page 1 of 3
Crim. Case No. 375-2016 and 376-2016
MANIFESTATION and MOTION
 5. Accused, thru undersigned counsel respectfully begs the
kind indulgence of this Honorable Court to give due
course to the instant motion.

PREMISES CONSIDERED, it is so respectfully prayed

for that this case be set for plea bargaining on 26 June 2018
at 8:30 o’clock in the morning.

Batangas City for Lemery, Batangas, 12 June 2018.

ROBERTO IÑIGO D. SANCHEZ

Counsel for the Accused
Zenaida Arcade, 43 M.H. Del Pilar St., Batangas City 4200
PTR No. 3025885 01.08.2018 Bats. City
IBP No. 1086954 01.08.2018 Bats. City
Roll No. 61644
MCLE Compliance Certificate No. V-0026006
valid until April 14, 2019
Telephone No. (043) 728 0002
ridslawoffice@gmail.com
srtclawoffice@gmail.com

NOTICE

OFFICE OF THE PROVINCIAL PROSECUTOR

Batangas City

OFFICE OF THE PROVINCIAL PROSECUTOR

Lemery, Batangas

THE CLERK OF COURT

RTC Branch 5
Batangas City
G R E E T I N G S:

Please submit the foregoing motion to the Honorable

Court immediately upon receipt hereof.

ROBERTO IÑIGO D. SANCHEZ

Page 2 of 3
Crim. Case No. 375-2016 and 376-2016
MANIFESTATION and MOTION
Copy Furnished:

OFFICE OF THE PROVINCIAL PROSECUTOR

Hall of Justice
Batangas City

OFFICE OF THE PROVINCIAL PROSECUTOR

Lemery, Batangas

Page 3 of 3
Crim. Case No. 375-2016 and 376-2016
MANIFESTATION and MOTION