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REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT


11TH Judicial Region
Branch V
Davao City

QUEEN RAVENA,
Plaintiff,
- versus -

CRIMINAL CASE No. 104501


(NPS-XI-04-INQ-151-00201)
FOR: RECKLESS IMPRUDENCE
RESULTING TO DAMAGE
IN PROPERTY

HUNSTMAN ERIC
Accused.
x ------------------------------x

MOTION FOR LEAVE


TO FILE DEMURRER TO EVIDENCE
The accused, Hunstman Eric, through counsel and unto this
Honorable Court, most respectfully states:
1. That the prosecution in the above entitled case has already
rested its case;
2. That the defense believes that the evidence of the
prosecution against the accused is insufficient to establish the guilt of
the accuses beyond reasonable doubt, thus, the defense prays for
leave to file demurrer to evidence in accordance with Section 33,
Rule 119 of the Rules of Criminal Procedure.
PRAYE R
WHEREFORE, premised on the foregoing consideration and in
the interest of justice, it is most respectfully prayed of this Honorable
Court that the aforesaid motion be granted.
Other just and equitable relief are likewise prayed for.

RESPECTFULLY SUBMITTED
4 APRIL 2016
DAVAO CITY, PHILIPPINES

ATTY. ELREEN PEARL A. AGUSTIN


Counsel for Accused
Notary Public for Davao City
Appointment No. 18464 until December 2016
PTR No. 2426856; Davao City; Jan 4, 2016
IBP No. 675345; Davao City; Jan 4, 2016
Roll of Attorneys No. 6473654
MCLE Compliance No. IV-00734/12 May 2015
Rebel Alliance Law Firm, Republic Building
Magallanes Street, Davao City

REQUEST FOR AND NOTICE OF HEARING


The Clerk of the Court
Metropolitan Trial Court, Branch 5
Davao City
Greetings.
Please submit the foregoing Motion for its consideration and
approval of the Honorable Court.

ATTY. ELREEN PEARL A. AGUSTIN


Counsel for Accused

ATTY. BERNIE C. PRINGASE


Counsel for Plaintiff
Supreme Chancellor Law Firm
Adminitration Building, Galactic Empire
Matina, Davao City
Greetings.
Please be notified that the foregoing Motion shall be submitted
for consideration and approval of the Honorable Court without further
arguments of counsel.

ATTY. ELREEN PEARL A. AGUSTIN


Counsel for Accused

Copy furnished through personal service:


ATTY. BERNIE C. PRINGASE
Counsel for Plaintiff
Supreme Chancellor Law Firm
Adminitration Building, Galactic Empire
Matina, Davao City
Received by:
Date:

REPUBLIC OF THE PHILIPPINES)


CITY OF DAVAO
) s.s
PROOF OF PERSONAL SERVICE
I, Clark Kent, of legal age, and having been duly sworn depose
and say that:
I am the messenger of Atty. Elreen Pearl A. Agustin, counsel for
the accuses in the case entitled "Queen Ravena vs. Huntsman Eric,"
Civil Case No. 104501, and that as such messenger I served upon
the counsel for plaintiff, Atty. Bernie Pringase, the foregoing Motion
for Leave to file Demurrer to Evidence filed in said case, by delivering
personally a copy of said motion upon said lawyer who confirmed
receipt thereof on April 6, 2016 as shown by his signature on the said
motion.
IN WITNESS WHEREOF, I have signed this affidavit on the 7th
day of April 2016 in Davao City, Philippines.
JURAT
SUBSCRIBED AND SWORN TO BEFORE ME, in the City of
Davao this 7th day of April 2016, the affiant exhibiting to me his
Driver's License No. 0918675633 issued by the Land Transportation
Office on December 8, 2014, and Community Tax Certificate No.
23245564 issued on January 4, 2016 at Davao City.

ATTY. ELREEN PEARL A. AGUSTIN


Counsel for Accused
Notary Public for Davao City
Appointment No. 18464 until December 2016
PTR No. 2426856; Davao City; Jan 4, 2016
IBP No. 675345; Davao City; Jan 4, 2016
Roll of Attorneys No. 6473654
MCLE Compliance No. IV-00734/12 May 2015
Rebel Alliance Law Firm, Republic Building
Magallanes Street, Davao City

Doc No. 106;


Page No. 37;
Book No. 38
Series of 2016.