This document is a motion filed in a Philippine regional trial court requesting a hold departure order be issued for an accused person. The motion alleges the accused is intending to leave the country to evade criminal prosecution for the charge of qualified theft. It provides identifying details of the accused and requests the court direct immigration authorities to place the accused on their hold departure order list to ensure they do not leave the Philippines and can be brought to trial. Notice is provided that the motion will be heard by the court on August 23, 2011.
This document is a motion filed in a Philippine regional trial court requesting a hold departure order be issued for an accused person. The motion alleges the accused is intending to leave the country to evade criminal prosecution for the charge of qualified theft. It provides identifying details of the accused and requests the court direct immigration authorities to place the accused on their hold departure order list to ensure they do not leave the Philippines and can be brought to trial. Notice is provided that the motion will be heard by the court on August 23, 2011.
This document is a motion filed in a Philippine regional trial court requesting a hold departure order be issued for an accused person. The motion alleges the accused is intending to leave the country to evade criminal prosecution for the charge of qualified theft. It provides identifying details of the accused and requests the court direct immigration authorities to place the accused on their hold departure order list to ensure they do not leave the Philippines and can be brought to trial. Notice is provided that the motion will be heard by the court on August 23, 2011.
This document is a motion filed in a Philippine regional trial court requesting a hold departure order be issued for an accused person. The motion alleges the accused is intending to leave the country to evade criminal prosecution for the charge of qualified theft. It provides identifying details of the accused and requests the court direct immigration authorities to place the accused on their hold departure order list to ensure they do not leave the Philippines and can be brought to trial. Notice is provided that the motion will be heard by the court on August 23, 2011.
Private Complainant, by counsel, under the direct control and supervision of the Honorable Public Prosecutor respectfully alleges that:
This is a criminal complaint for Qualified Theft under the Revised Penal Code against the accused.
Private complainant has reliable information that said accused is intending to go abroad to evade criminal prosecution.
Consequently, to insure that accused do not leave the country to evade criminal prosecution and to guarantee that he is properly brought before the bar of justice to face his charge, it becomes imperative that he be placed in the “hold departure order” list of the Bureau;
For the guidance and information of the Court, we furnish the complete data, regarding accused ________________________________ to wit; Complete Name :
Sex :
Civil Status : Complete Address :
Date of Birth :
Birthplace :
Age : ________________________________
________________________________
________________________________
________________________________
________________________________
________________________________
________________________________ Photocopy of the photograph of the ________________________________ is hereto attached as Annex “A” for easy reference.
WHEREFORE, premises considered, it is respectfully prayed that this Honorable Court issue an order directing the Commissioner of the Bureau of Immigration to place accused ________________________________ in their “Hold Departure Order” list.
Other relief and remedies just and equitable under the premises are prayed for.
Please be notified the undersigned has requested the Branch Clerk of Court to include the foregoing Motion in the Court Calendar on August 23, 2011 at 8:30 a.m. that counsel and matter may be heard.
JEFFREY PARIL
Copy furnished:
Office of the City Prosecutor
Imus City, Cavite
ATTY. RAPHAEL CORONADO
2nd Floor, RCVJ Building,
Don P. Campa Avenue, Barrio Uno,
2662 Dasmarinas City, Cavite
ATTY. ALEXANDER LIQUIGAN
Unit 3C, De Quiroz Bldg.,
Aguinaldo Highway, Perpetual Village,
Palico III, Imus City, Cavite
Explanation Copy of the Motion was furnished to the respondent by private courier due to the distance of the undersigned from the said parties, making personal service thereof not practicable.
