REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

7th Judicial Region
BRANCH 13
CEBU CITY

PEOPLE OF THE PHILIPPINES CRIM. CASE NO. R-CEB-19-

Plaintiff, 06146/47-CR

-versus- FOR: VIOLATION OF SECS. 5

AND 11 ART. II OF RA 9165
LEUNAM JUARIO CODILLA (THE COMPREHENSIVE
a.k.a. YONAM JUARIO DANGEROUS DRUGS ACT
CODILLA, OF 2002)
Accused.
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MOTION TO WITHDRAW
THE MOTION TO RELEASE ON RECOGNIZANCE

ACCUSED LEUNAM JUARIO CODILLA a.k.a. YONAM

JUARIO CODILLA, through the undersigned counsel and unto the
Honorable Court, most respectfully allege and move that:

1. On August 2, 2019, accused Leunam Juario Codilla a.k.a.

Yonam Juario Codilla pleaded guilty to the lesser offense
from Sec. 5 to Sec. 12, Art. II, of R.A. 9165 and Sec. 11 to
Sec. 12, Art. II, of R.A. 9165 in accordance with the Plea
Bargaining Framework on Drug Cases issued by the
Supreme Court (A.M. No. 18-03-16-SC).

2. On August 8, 2019, accused Leunam Juario Codilla a.k.a.

Yonam Juario Codilla filed an Application for Probation.

3. On September 6, 2019, accused Leunam Juario Codilla

a.k.a. Yonam Juario Codilla filed a Motion to Release on
Recognizance.

4. The Probation Office, Cebu City submitted post-sentence

investigation report of the accused unto this Honorable
Court.

5. In view of the submission of the post-sentence

investigation report, the accused moves that the Motion
for Release on Recognizance be withdrawn.

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 PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed unto this Honorable Court that an Order be issued to GRANT
the Motion to Withdraw the Motion for Release on Recognizance.

All other reliefs just and equitable under the foregoing are
likewise prayed for.

RESPECTFULLY SUBMITTED. February 17, 2020. Cebu City,

Philippines.

P.B. LABRADO AND PARTNERS LAW OFFICE

Counsel for the Accused
Room 202, 2nd Floor, Aniceta Bldg.,
Osmena Blvd., Cebu City
Tel. No. (032) 4053099

MARC CHRISTIAN H. TANGPUZ

Roll of Attorneys No. 72435
PTR No. 502224; Cebu Province, January 10, 2020
IBP No. AR43284160; Cebu Province, January 10, 2020
MCLE Compliance No. VII-0001477 valid until April 14, 2025
Room 202, Aniceta Bldg. Osmena Blvd., Cebu City
Cell No. 0939 397 6604
marcchristiantangpuz@gmail.com

REQUEST & NOTICE

THE BRANCH CLERK OF COURT

RTC Branch 13 – Cebu City
Cebu City Hall of Justice
Qimonda Bldg., North Reclamation Area
Cebu, Philippines

HANDLING PUBLIC PROSECUTOR

Office of the City Prosecutor
3rd Floor, Department of Justice Building
Department of Agriculture Compound,
M. Velez Street, Brgy Guadalupe, 6000 Cebu City

Greetings! Please submit and set the foregoing Motion to

Withdraw the Motion for Release on Recognizance for consideration
of the Honorable Court on February 21, 2020 at 8:30 o’clock in the
morning with the presence of counsel and further argument.

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 Honorable Prosecutor shall kindly take notice. Thank you very
much.

Respectfully submitted. February 17, 2020. Cebu City,

Philippines.

MARC CHRISTIAN H. TANGPUZ

Proof of Personal Service:

HANDLING PUBLIC PROSECUTOR

Office of the City Prosecutor
3rd Floor, Department of Justice Building
Department of Agriculture Compound,
M. Velez Street, Brgy Guadalupe, 6000 Cebu City

Received by: __________

Date: ________________