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TO: ATTY.

MELISIA CARIAGA, Junior Associate

FROM: ATTY. JANE DOE, Junior Partner

SUBJECT: INTER OFFICE MEMO FEEDBACK

DATE: October 30, 2019

FACTS CHECK

▪ If RA 10592 expressly amended Art 29,94,97,98 and 99 of RPC, then why did you based your brief
answer in Art 29 instead of RA 10592

▪ Sanchez is not a recidivist, although his crimes are in the same title, the final judgment of his 2nd crime
came out first before the 1999 –GR No 131116 case

▪ The final judgment of the first crime came after the final ruling of the 1999 case

▪ Our client will not like the presentation since the conclusion is weak because you did not include a lot
of facts to consider. Legal basis is also lacking

▪ You did not indicate the series of events as to why Sanchez was restrained from an early release

▪ For the indemnity compensation charges, sanchez did not pay?

▪ More facts are available for consideration

▪ The IRR was passed to apply prospectively, but you did not indicate that SC granted a petition that the
GCTA will apply retroactively to the convicts no later than 2013

▪ The IRR expressly excludes the prisoners convicted of heinous crimes, but in GCTA lAW It does not

▪ What about the GOOD CONDUCT that he performed while in prison

▪ You did not consider the shabu that was found in cell

▪ Sanchez violated the prison rules under par 32 which prohibits ….

▪ The refrigerator, tv and aircon that was seized by BuCor

▪ GR 121039-45 – definition of heinous crimes, penalizes death penalty for rape

▪ You also did not indicate annex p of the uniform manual which…

▪ What are the facts that prejudices the possible release of Sanchez
CONSTRUCTION OF IDEAS

▪ Republic Act No 10592 not “No. Republic Act 10592”

▪ Omit adding a lot of unnecessary facts, ex. Some provisions of the act not useful

▪ Lacking facts about the other cases of Sanchez

▪ Sequence of events is not chronological

▪ Forgot to add DISCUSSION part, how the law applied

▪ On p. 4 &5 , no background of the case given. It was only the ruling. It will look irrelevant since the
facts are not written. Copy pasted a lot

▪ The court ‘modified the rtc” what is the ruling in the rtc?

▪ Issue is not clear, should have included sub issue

FORMAT

▪ Proper spacing in P.1 Par 1, p.5 par 2, p.4 par 3

▪ Margin on the left and upper area is not followed

▪ Alignment of heading

▪ Names must be bold

▪ Some figures has Php, others don’t have

▪ Did not indicate position of the partners

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