Motion For Leave of Court To File Demurrer To Evidence

 

Republic of the Philippines NATIONAL CAPITAL JUDICIAL REGION REGIONAL TRIAL COURT  Branch ____, ______________ City PEOPLE OF THE PHILIPPINES, Plaintiff,

CRIM. CASE NO. C-100823 and C100824

 –   versus – 

FOR: Acts of Lasciviousness in relation to Section 5 (b) of R.A. No. 7610

ROLANDO SALINAS y ESTRADA , Accused. x-------------------------------------------x

MOTION FOR LEAVE OF COURT TO FILE DEMURRER TO EVIDENCE COMES NOW, the accused  ROLANDO SALINAS y ESTRADA, assisted by the ______________________________, through the undersigned ________________________, and unto this Honorable Court, most respectfully avers:

1.  That this Honorable court had already made a ruling on the prosecution’s formal offer of evidence on February 15, 2019; 2.  That the prosecution’s evidence is inherently weak, unsubstantiated, and insufficient to prove the guilt of all the accused beyond reasonable doubt; and 3.  That in view thereof, the defense prays that it be allowed by this Honorable Court to file its demurrer to evi evidence dence WITH LEAVE OF COURT tto o be able to point out in detail the weakness of the prosecution’s evidence necessitating the dismissal of this case and so as not to further waste the precious time of this court. PRAYER WHEREFORE , premises considered, it GRANTED, is most respectfully prayedaccused, of this Honorable Court that the instant motion be allowing herein through counsel, to file a DEMURRER TO EVIDENCE, with leave of court.

Other reliefs and remedies available under the premises are likewise prayed for. Caloocan City. February 19, 2019. ATTORNEY  ATTY ___________________________ Branch Clerk of Court Regional Trial Court Branch ___________ _________________ ______

Greetings:

 

  Please submit the foregoing motion for the kind consideration and approval of this Honorable Court on FEBRUARY 22, 2019 (FRID Y) at 8:30 o’clock in the morning. ATTY ______________________

Copy furnished : ACP __________________________________ _ ___________________________________ __ Public Prosecutor Office of the City Prosecutor ____________________________ _______________________________