Republic of the Philippines

Fourth Judicial Region

REGIONAL TRIAL COURT
Branch 4
Pallocan West, Batangas City
THE PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NOS.
Plaintiff, 25166 & 25157

versus for

FERNANDO REY CATILO & GEMMA VIOL. OF ART. II SECS. 5 & 11 OF RA

TARCELO, 9165
Accused.
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MOTION TO ENTER INTO PLEA BARGAINING
COMES NOW, BOTH ACCUSED through the undersigned counsel, and unto this
Honorable Court, most respectfully avers the following:
That both accused become aware of the recent jurisprudence of the Supreme Court in the
case of SALVADOR A. ESTIPONA, JR., Petitioner, vs. HON. FRANK E. LOBRIGO, Presiding
Judge of the Regional Trial Court of Legazpi City, Branch 3, and PEOPLE OF THE PHILIPPINES,
G. R. No. (G.R. No. 226679; August 15, 2017) and A.M. No. 18-03-16-SC (Adoption of the Plea
Bargaining Framework in Drugs Cases) dated April 10, 2018, allowing plea bargaining in drugs
cases;
That after it has been explained to them the repercussions of the plea bargain in drugs case,
they decided to avail of the same and that they are willing to plead guilty to a lesser offense;
That both accused are willing to undergo Drug Dependency Assessment Examination.
WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court
that both accused be allowed to plead guilty to a lesser offense under Section 12, Article II of RA
9165.
Other reliefs, just and equitable under the premises are likewise prayed for.
Batangas City, July 17, 2019.
PUBLIC ATTORNEY’S OFFICE
DEPARTMENT OF JUSTICE
BATANGAS DISTRICT OFFICE
Counsel for the Accused
By:
JOSE MICHAEL D. MASANGKAY
Public Attorney 2
Roll No. 53480
MCLE Compliance No. VI-0010997
The Branch Clerk of Court
RTC- Branch 4-Batangas City
Greetings:
Please take notice that this Motion will be submitted for resolution of this Honorable Court
immediately upon receipt hereof.
JOSE MICHAEL D. MASANGKAY
Copy furnished:
The City Prosecutor of Batangas