Republic of the Philippines

Metropolitan Trial Court in Cities

Branch 1
First Judicial Region
Baguio City

PEOPLE OF THE PHILIPPINES,

- versus - Crim. Case Nos. 2468

For: Falsification of
PEDRO JUAN y PEREZ, Commercial Document

Accused
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APPLICATION FOR PROBATION

ACCUSED, through the undersigned counsel and unto this

Honorable Court, most respectfully applies for probation under the
provisions of Presidential Decree No. 968 as amended and states that:

1. On 18 September 2019, accused was convicted of the crime of

Falsification of Commercial Document and was sentenced to suffer
one (1) year of prision correctional as minimum to four (4) years and
two (2) months of prision correctional as maximum and to pay a fine
of P3,000.00, with subsidiary imprisonment in case of insolvency or
non-payment;

2. The crime for which the accused was convicted is not an offense
against national security or public order;

3. Accused has not been previously convicted by final judgment of any

offense punishable by imprisonment of not less than one month and
one day and/or fine of not less than two hundred pesos;

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 4. Accused has not been once placed on probation under the provisions
of Presidential Decree No. 968, otherwise known as the Probation
Law of 1976, as amended;

5. Accused has all the qualifications and none of the disqualifications to

avail of the benefits of the Probation Law.

WHEREFORE, premises considered, it is most respectfully prayed of

this Honorable Court that the Application for Probation be referred to the
Parole and Probation Officer of Baguio City for the requisite post-sentence
investigation and thereafter, the application for probation be approved.

Other reliefs just and equitable in the premises are likewise sought.

Baguio City, Philippines. September 23, 2019.

ATTY. TANADA R. TOVERA

Counsel for the Accused

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 NOTICE OF HEARING

THE BRANCH CLERK OF COURT

MTCC - Branch 1
Baguio City

Greetings!

Please submit the foregoing motion to the Honorable Court on

September 27, 2019 at 9:00 in the morning for its favorable consideration
and approval.

ATTY. TANADA R. TOVERA

Copy furnished by personal service:

PROSECUTOR KIMMY P. ALLENDA

Office of the City Prosecutor, Baguio City

PAROLE AND PROBATION OFFICE

Baguio City

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