REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
NATIONAL CAPITAL JUDICIAL REGION
QUEZON CITY
BRANCH_____
PEOPLE OF THE PHILIPPINES,
Plaintiff,
Criminal Case
No__________For: Estafa
HECTOR THOMAS ARNALDO
NAVASERO,
Accused.
x------------------------------------------x
URGENT MOTION FOR
PERMISSION/AUTHORITY
TO TRAVEL ABROAD
Accused HECTOR THOMAS ARNALDO NAVASERO, by
counsel, respectfully states that:
1. On _________, the Honorable Court issued a Watch List
Order on the Accused in the captioned cases, requiring him to ask for
leave of court in order to travel abroad.
2. In this regard, Accused respectfully prays that he be
allowed to travel to:
3. Accused will book his tickets and accommodations only
when the Honorable Court grants this Motion. He undertakes to
submit to the Honorable Court copies of his bookings once available.
Accused may be reached anytime through his personal roaming
mobile number_______.
4. A copy of the biopage of Accused’s Philippine Passport
No. ____________ is attached as Annex “A”.
5. The instant motion is anchored on the Bill of Rights,
which provides that the constitutional right to travel is a guaranteed
right which may be impaired only under certain exceptions, to wit:
1
“Article III
Bill of Rights
SECTION 6. The liberty of abode and of changing the
same within the limits prescribed by law shall not be
impaired except upon lawful order of the court. Neither
shall the right to travel be impaired except in the
interest of national security, public safety, or public
health, as may be provided by law.”
8. With due respect, the instances warranting the restriction
of Accused’s constitutional right to travel are not availing in this case
as there is no threat to national security, public safety, or public
health.
9. Accused guarantees that he will abide by whatever
conditions the Honorable Court may impose for his foreign travels.
10. Moreover, Accused assures the Honorable Court that he
will return to the country on the return dates specified above, and
that he will continue to abide by the Orders of the Honorable Court
and the terms and conditions of his bail.
11. For the above reasons, Accused humbly requests the
Honorable Court to allow him to travel abroad to the places and on
the dates specified above.
RELIEF
WHEREFORE, premises considered, it is respectfully prayed
that the Honorable Court ALLOW the Accused to travel abroad to:
Accused likewise, prays for other reliefs that may be just and
equitable under the premises.
Taguig City for Quezon City, 17 April 2017.
ANDREW GONZALES
Collaborating Counsel for the Accused
2
8th floor Hanjin Bldg. 1128 38th St. University
Parkway North Bonifacio Taguig City, 1634, Taguig,
Roll of Attorneys No.
IBP No.
PTR No.
MCLE Compliance No.
Copy furnished and notice of hearing:
Medialdea Ata Bello & Suarez
Private Prosecutor
17th Floor, The Taipan Place
F. Ortigas Jr. Road, Ortigas Center
Pasig City
Office of the City Prosecutor
Quezon City
Greetings:
The undersigned counsel shall submit the foregoing Urgent
Motion for the consideration and approval of this Honorable Court
on 19 April 2018 at 8:30 a.m. or at the earliest date convenient to the
calendar of the Honorable Court. This Urgent Motion is being filed
with the Honorable Court and served upon the Public and Private
Prosecutor at their last known addresses via personal service.
ANDREW GONZALES
3
Republic of the Philippines)
____ City, Metro Manila )
AFFIDAVIT OF SERVICE
Affiant CHARLES VILLAREAL, Filipino, legal age, with postal address at 8th
floor Hanjin Bldg. 1128 38th St. University Parkway North Bonifacio Taguig City,
1634, Taguig, hereby declares and states that:
On 17 April 2018 in accordance with Sections 3 and 5 in relation to
Sections 10 and 11 of Rule 13 of the 1997 Rules of Civil Procedure, Affiant caused
to be filed by personal service with the Honorable Office copies of the foregoing
Urgent Motion at the following address:
Regional Trial Court, Branch 84
Quezon City
after furnishing a copy thereof via personal service to:
Medialdea Ata Bello & Suarez
Private Prosecutor
17th Floor, The Taipan Place
F. Ortigas Jr. Road, Ortigas Center
Pasig City
And
Office of the City Prosecutor
Quezon City
IN WITNESS WHEREOF, Affiant has hereunto affixed his signature at
____ City, Metro Manila, Philippines, this _____________.
CHARLES VILLAREAL
I certify that 17 April 2018, before me, a Notary Public duly authorized in
Quezon City to take acknowledgment, personally appeared Affiant, exhibiting to
me his N03-98-253761, who was identified by me through competent evidence of
identity to be the same person described in the foregoing instrument, who
acknowledged before me that his signature on the instrument was voluntarily
affixed by him for the purposes stated therein, and who declared to me that he
has executed the instrument as his free and voluntary act and deed.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed my
notarial seal on the date and at the place above written.
Doc. No. ____;
Page No. ____;
Book No. ____;
Series of 2018.
