REPUBLIC OF THE PHILIPPINES

IN THE 5TH MUNICIPAL CIRCUIT TRIAL COURT

OF TALISAY-LAUREL
PROVINCE OF BATANGAS

PEOPLE OF THE PHILIPPINES,

Plaintiff,
Crim Case No.: MCTC-13-004
– versus – For Violation of PD 1866

AQUILINO MANIMTIM
y PURDUNZALAN,
Accused.
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OMNIBUS MOTION TO ENTER INTO PLEA BARGAINING

WITH PROPOSAL AND MOTION TO DISMISS

COMES NOW, accused AQUILINO MANIMTIM y PURDUNZALAN,

through the undersigned counsel, unto the Honorable Court, most respectfully
avers, THAT:

1. The accused stands charged for the crime of Violation of PD 1866

as amended by Republic Act No. 8294 otherwise known as Illegal
Possession of Firearm and Ammunition, and is presently pending
before the Honorable Court;

2. This case stemmed from an incident that transpired at on or about

January 26, 2013 at about 11:40 o’clock in the evening at Sitio
Looc Tabla, Pulo Island, Talisay, Batangas where the accused was
allegedly found in possession of two (2) unlicensed firearms and
ammunitions, to wit: (a) .22 revolver (Paltik); and (b) Armscor
cal .45 pistol with Serial No. 1386416, during election period;

3. The accused now faces three (3) offenses, to wit:

a. Violation of Presidential Decree No. 1866 for Illegal Possession

of unlicensed .22 caliber firearm and ammunitions before this
Honorable Court;

b. Violation of Presidential Decree No. 1866 for Illegal Possession

of unlicensed .45 caliber pistol firearm and ammunitions
before the Regional Trial Court, Branch 83 of Tanauan City,
Batangas; and

c. Violation of the Omnibus Election Code.