REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT

First Judicial Region
Branch 3
Baguio City

PEOPLE OF THE PHILIPPINES

Plaintiff,

versus CRIMINAL CASE. B-11-2019-25

FOR: VIOLATION OF BATAS PAMBANSA
BLG. 22

PETER A . SANTIAGO,
Accused.

X------------------------------------X

MOTION FOR LEAVE OF COURT to file

DEMURRER TO THE EVIDENCE

Comes Now, Accused, through counsel, respectfully states:

1. That the prosecution has presented its witnesses and has formally offered its
evidence;

2. That the admissibility of exhibits so offered had been resolved in the order dated
August 2, 2019 which was received by the undersigned counsel on August 4, 2019;

3. That the accused seeks leave of court to file a Demurrer to the Evidence. on the
ground that the evidence presented by the prosecution is not sufficient to warrant a
conviction of the guilt of the accused beyond reasonable doubt;

4. That this motion is filed in good faith and not for the purpose of delaying the
proceedings of this case;

WHEREFORE, it is respectfully prayed that the accused be granted Leave of

Court to file a Demurrer to the Evidence.

Baguio City, Philippines, August 8, 2019.

ATTY. DEVANIE D.DUAMGCAO

Counsel for the Accused
Until December 31, 2020
Room 301,JMD Bldg. Lower Gen. Luna Rd,
Baguio City
PTR No. 564589/Baguio City/1-9-17
Roll of Atty. No. 12297
IBP O.R. No. 784512 Baguio Benguet
MCLE No. III-852963, 07-20-2018
 NOTICE OF HEARING

Pros. ________________
The City Prosecutor’s Office

Please be notified that the undersigned has set the hearing of this motion for
leave of court for the consideration of the Honorable Court on ___________ at 8:30
am without further oral argument and sans appearance of counsel.

Thank you.

Atty. Devanie D. Dumagcao

Name and signature of Counsel

Copy furnished:

Pros. _________

Office of the City Prosecutor