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Republic of the Philippines 1  MUNICIPAL CIRCUIT TRIAL COURT PAMPLONA-AMLAN-SAN JOSE Pamplona, Negros Oriental st

PEOPLE OF THE PHILIPPINES, Plaintiff,

CRIMINAL CASE NO. 2626 For: Grave Slander 

-versusJENALYN DE GUZMAN, JOCELYN DE GUZMAN, SHEILA SEIT, WILMA SIENES a.k.a ALMA SIENES, Accused. X----------------------------/

OMNI OM NIBU BUS S MOTI MOTION ON (MOTION TO QUASH INFORMA INFORMATION, TION, RECALL WARRAN WARRANT T OF ARREST AND REINVESTIGA REINVESTIGATION) TION)

COME NOW DEFE DEFENDA NDANTS, NTS, by couns counsels els and unto this Honor Honorable able Court, most respectfully move to quash the information filed against the defendants on the following grounds: 1) Th That at the the ca case se ha hass no nott un unde derrgo gone ne re requ quis isit itee Ba Bara rang ngay ay Co Conc ncil ilia iati tion on  proceedings. 2) That the facts charged do not constitute an offense. 3) That the facts contains averment which if true would constitute a legal excuse or justification. FURTHERMORE, DEFENDANTS move to recall the warrant of arrest issued against the accused on the ground that it was issued without probable cause. FINALLY, DEFENDANTS respectfully move for the reinvestigation of the case on the following grounds: 1) That minutes of the barangay mediation proceedings were incomplete. 2) That the alleged defamatory statements were made in a barangay mediation  proceedings, which which are privileged and cconfidential onfidential in nature nature..

ARGUMENTS Defendants are indicted for committing the crime of " Grave Slander " that is  punished under the Article 358 1 st phras phrasee of the R Revise evised d Pen Penal al Code; S Said aid  provision states that:

 Motion to Quash Criminal Criminal Case 2626

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Art. 358. Slander. — Oral defamation shall be punished by arresto mayor in its maximum period to prision correccional in its minimum  period if it is of a serious and insulting nature; otherwise the penalty shall be arresto menor or a fine not exceeding 200 pesos.

DEFEND DEF ENDAN ANTS, TS, HO HOWEV WEVER ER,, MO MOST ST RES RESPEC PECTF TFULL ULLY Y SU SUBMI BMIT T THE FOLLOWING ARGUMENTS: dismiss the cas casee bec becaus ausee it has 1. The court should dismiss not undergone the requisite Barangay conciliation  proceeding.

The case should be dismissed for non-compliance with the provisions of Book  III, Title I, Chapter 7 (Katarungang Pambarangay), of Republic Act No. 7160 (The Local Government Code of 1991). As held in Agbayani v v.. CA 1, where the criminal complaint (a) did not state that it is one of the excepted cases, or (b) it did not al alle lege ge prio priorr avai availm lmen entt of sa said id co conc ncil ilia iati tion on pr proc oces ess, s, or (c (c)) di did d no nott ha have ve a certification that no conciliation or settlement had been reached by the parties, the case should be dismissed. While the parties have previously undergone Barangay Conciliation, the subject matter of the complaint before the Lupon was different. The dis disput putee su subje bject ct for rec reconc oncili iliati ation on dur during ing the sa said id Bar Barang angay ay Con Concil ciliat iation ion  proceeding was the alleged defamatory remarks on the Facebook page of accused, not the remarks uttered DURING the SAME Barangay Conciliation proceeding. Theref The refore ore,, the cas casee bef before ore thi thiss Hon Honora orabl blee Cou Court, rt, whi which ch is abo about ut the all allege eged d defamatory remarks uttered during the Barangay Conciliation Proceedings has not yet undergone the requisite Barangay Conciliation proceedings. Subsequently, the case should be dismissed for failure to undergo mandatory Barangay Conciliation  proceedings. 2. The all allege eged d defam defamato atory ry stat stateme ements nts wer weree utter uttered  ed  in th e cours rsee of mediation/conciliation  proceedings upon the queries of Lupon Members thereby negating the element of malice necessary in the crime of slander.

The information states that the utterance of the alleged defamatory words was done in the presence of the mediator. That, in itself, indicates that words would have been uttered in the middle of a proceeding and questioning, thereby making them non-malicious. As such, the facts stated in the information do not constitute a crime.  Nevertheless,, the Honorable Prosecutor ba  Nevertheless based sed his findings of slander pri primarily marily on the Minutes of the Barangay Conciliation proceeding. However, the minutes 1

 G.R. No. 183623, June 25, 2012  Motion to Quash Criminal Criminal Case 2626

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su subm bmit itte ted d by th thee ba bara rang ngay ay an and d at atta tach ched ed to the the co comp mpla lain intt is no nott a fa fait ithf hful ul reproduction of what really transpired in the mediation proceedings. It did not relay rel ay in det detail ail how th thee st state atemen ments ts we were re mad made. e. Ins Instea tead, d, th thee utt uttera erance ncess of the accused were paraphrased and put into writing in a manner convenient to the Secretary, who made such minutes. Only the alleged defamatory remarks were transcribed and the preparatory questions were left out. In fact, upon reading of the minutes, there is no clear flow of what actually went on during the conciliation  proceedings, to wit: September 10, 2015 @ 10:00AM (Excerpt) Kag.. Bar Kag Barrer reraa

: Sa wal walaa pa ni m mahi ahitab tabo o ma mayo yo b bam am o o(si (sic) c) ug rel relasy asyon? on?

Jenalyn De Guzman: April 28, 2015, alas 8:00 sa buntag nangayo ka (Linda Gentelizo) ug asa paliton ang baso sa buko juice ug unsaon  pagtimpla pero gay aba-yaba aba-yaba ka nga imo ko I rreport eport BIR. Sheila Seit: Nagkita mi, nagkatagbo mi nangutana ko ug ngano naapil ko sa Face Book, wala naku siya gitulisok, miingon siya nga gitulisok  daw siya naku ug nga gihulga kuno siya naku, nga dalaga kuno kong  buhat ug ngano kuno nga ga iskandalo iskandalo ko. Kag. Ba Kag. Barr rrer era: a: Di Dili li ni fi fina nall ng ngaa mo motu tuo o or di dili li mu mutu tuo o sa inyo inyong ng gipangbatbat ron, kay sa dagan sa 2nd  hearing galabuga ang inyong istorya ug unending case ni… Here, Kagawad Barrera asked about their relationship and yet Jenalyn de Guzman allegedly went on to narrate what happened on May 12, 2015. September 29, 2015 @ 9:00AM Excerpt  Linda Lin da Gen Gentil tilizo izo:: Kan Kanang ang ako akong ng gi com compla plaint int ako akong ng ipa ipaday dayon on aga agains instt the respondents. Jenaly Jen alyn n de Guz Guzma man n : Ma May y 12, ga gahis hisgot got ug pag pagpan pangaw gawat at ug ka kandi nding ng either 2013 or 2014 at 9 p.m. Ang kanding gikuha ni  Noel Gentelizo, ug si Mama ug akong iyaan ang nakakita (1 kanding nga laki), ilihawon to mga 1 year  kapin na. Naa may record daan iyang anak, siya pay misulong sa balay, gay aba-yaba anang May 12 pero iy iyan ang g gi gita taba bana nana na an ang g gibu gibuha hatt sa iy iyan ang g an anak ak.. Mga Mga ulutanon, galay, kalamungay mga atis iyang gipang pupo ug gidala sa lungsud lungsud ug gibaligya. It would appear that Jenalyn de Guzman uttered these words without any direction or purpose. First, she was talking about the stealing of the goat then all of  a sudden, she was talking about vegetables. It just does not make any sense. The entire record does not make sense. Clearly, the minutes are very incomplete to

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even provide the context upon which the alleged defamatory statements were uttered, if in fact they were uttered maliciously. There was even no indication of  any altercation between the accused and private complainant which could have  possibly caused the the accused to utte utterr the alleged defa defamatory matory remarks. Luckily, accused Jenalyn de Guzman was able to make a voice recording of  the entire proceedings using her cellphone. The accused is willing to present  before the court the voice recording of the conversation that transpired during the September 29, 2015 mediation proceedings. Based on the voice recording dated Sept. 29, 2015, prior to the utterance of  accused Jenalyn De Guzman, the mediator raised the question of what happened on May 12. In her candor, Jenalyn simply narrated that on May 12, either 2013 or  2014 at 9:00PM, her mother and auntie saw Private complainant Noel Gentilizo stole 1 male goat, that was 1 year old and could be slaughtered already, and that her (Linda Gentilizo) son has already a record. Jenalyn added that though she was not abl ablee to wit witne ness ss the inc incide ident nt per person sonall ally y, he herr mot mother her,, acc accuse used d Jo Jocel celyn yn De Guzman, and her aunt, accused Alma Sienes, can attest to her statement, the two having witnessed the incident themselves. Since the two other accused were mentioned by Jenalyn De Guzman, the medi me diat ator or aske asked d Al Alma ma Si Sien enes es ab abou outt wh what at sh shee ha had d wi witn tnes esse sed d on Ma May y 12 12.. In response, she made the following statement: “May 12, 9pm ang kanding kalubog sa balay, may nihunong nga motor ug kigarga sa motor kauban ang ig-agaw nga taga tayasan. Si Noel Gentilizo ang gakarga sa motro. (May 12, 9PM the goat was resting near our house when somebody in a motorcycle stopped and loaded the goatt in the mot goa motorc orcycl yclee tog togeth ether er wit with h his cou cousin sin who is fro from m Taya ayasan san.. Noe Noell Gentilizo was the one who loaded the goat in the motorcycle). The accused Alma Sienes’ utterances were merely in answer to the question of the mediator and a narration of what she had personally witnessed during the said date and time. After Alma Sienes gave her testimony, Jenalyn De Guzman again told the mediator that her mother also had personally witnessed the said incident and is willing to testify. The mediator then asked accused Jocelyn to narrate on what she saw on May 12. In response, Jocelyn uttered the following statement: “May 12, 2015, alas 9:00 sa gabii akong nakita si Noel Gentilizo nga giaswat and kanding kauban sa iyang ig-agaw taga tayasan. Si Noel Gentilizo ang ga karga sa motor.” (May 12, 2015, 9:00 o’clock in the evening, I saw Noel Gentilizo carry the goat together with his cousin who is from tayasan. Noel Gentilizo was the one who lo load aded ed th thee go goat at on th thee mo moto torc rcyc ycle le). ). Ag Agai ain, n, ac accu cuse sed d Jo Joce cely lyn n de Gu Guzm zman an’’s utterances were made in answer to the query of the mediator and serves as her  attestation to Alma’s Alma’s testimony on what she also personally witnessed on the same

 Motion to Quash Criminal Criminal Case 2626

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day. Thus, the utterances made by accused Jenayn De Guzman, Alma Sienes and Jocelyn De Guzman were all made in the course of the barangay conciliation  proceedings and as answers to the queries made by the mediator. Such statements made by the accused were not intended to be humiliate the complainants but rather  to shed light to the issues and to assist the mediator to understand better the controversy between accused and private Complainants. If the accused are not allowed to defend themselves during the Barangay Conciliation proceedings for  fearr of bei fea being ng cha charg rged ed for sla slande nderr, the then n no ami amicab cable le set settl tleme ement nt wil willl eve everr be achieved at this level and the whole proceeding’s purpose is put to naught. In short, these alleged utterances were not malicious but in fact called for by the circumstances. With respect to the allegation against accused Sheila Seit, the minutes of the mediation proceedings dated September 10, 2016 do not reflect any record that Sheila uttered the following statement: “Kawatan man gud na sya, watchinangga lang” (She is a thief and very clever). Upon review of the voice recording of the said proceedings, Sheila merely narrated the incident that occurred on April 28, 2015. Although Although there occurred raising of voice voicess on both parties parties,, the accused and  private complainant Linda Gentilizo, accused Sheila Seit never uttered the alleged defama def amator tory y sta statem tement ent.. Suc Such h all alleg egati ations ons are cle clear ar fab fabric ricati ations ons des design igned ed by complainants to implead Sheila Seit in the case. Again, Jenalyn De Guzman is willing to present in court the voice recording she had on the September 10, 2016 mediation proceedings in the barangay. 3. The all allege eged d defam defamato atory ry stat statem ement entss utter uttered ed by the accused, as stated, were made in a mediation/conciliation proceedings, making them  privileged, confidential, and inadmissible in evidence against the accused.

The Bara Barangay ngay Medi Mediation ation/Conc /Concilia iliation tion proc proceedin eedings gs provi provides des the disp disputing uting  parties a venue to search for a solution that is mutually acceptable to them. The Punong Barangay and the Community Conciliators (Lupon Members) only assist the parties in discussing the possible amicable settlement to their disputes. In the  process of reaching a solution, parties should have the freedom to express their  and expected to exercise candor in answering questions raised by the conciliators. While the Revised Katarungang Pambarangay Law 2 and the Administrative Circular No. 14-933, are silent on the confidentiality and privileged nature of  inform inf ormati ation on obt obtain ained ed dur during ing Bar Barang angay ay Con Concil ciliat iation ion pro procee ceedin dings, gs, the rul rules es 2

 Sectons 399-422, Chaper VII, Tile I, Book III of he Local Governmen Code of 1991.

3

 Guidelines on the Katarungang Pambarangay Conciliation proceedings.  Motion to Quash Criminal Criminal Case 2626

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regarding conciliation-mediation proceedings in RA 9285, Labor Code and A·M.  No, 11-1-6-SC-PHILJA, 11-1-6-SC-PHILJA, suppletor suppletorily ily apply apply.. Unde Un derr RA 92 9285 854, the Ka Katar tarang angang ang Pam Pambar barang angay ay,, bei being ng an alt altern ernati ative, ve, co comm mmun unit ityy-ba base sed d me mech chan anis ism m for for di disp sput utee re reso solu luti tion on,, wo woul uld d fa fall ll un unde derr th thee definition of Alternative Dispute Resolution System, to wit: "Alter "Alt erna nati tive ve Di Disp sput utee Re Reso solu luti tion on Sy Syst stem em"" me mean anss an any y pro proce cess ss or   procedure used to resolve a dispute or controversy controversy,, other than by ad adju judi dica cati tion on of a pres presid idin ing g ju judg dgee of a co cour urtt or an of offi fice cerr of a government gover nment agency agency,, as defined in this Act, in which a neutral third  party participates to assist in the resolution of issues, which includes arbitration, mediation, conciliation, early neutral evaluation, mini-trial, or any combination thereof .” Both the proceedings in Katarungang Pambarangay and ADR ADR are facilitated by  private individuals. Furthermore, both proceedings aim to promote party autonomy in the resolution of disputes or provide freedom of the parties to make their own arrangement to resolve disputes to help achieve speedy and impartial  justice and de-clog court dockets. Accordingly Accordingly,, provisions in RA 9285, including the confidentiality and privileged clause, can be interpreted and made applicable to the Karatungang Pambarangay. The only exception under the law is that it cannot  be interpreted to repeal, amend or modify the jurisdiction of the Katarungan Pambarangay.5  Unde Un derr Se Sec. c. 9 of RA 92 9285 85,, in info form rmat atio ion n ob obta tain ined ed th thro roug ugh h me medi diat atio ion n  proceedings shall be privileged and confidential. It shall not be subject to discov dis covery ery and sha shall ll be ina inadmi dmiss ssibl iblee in any adv advers ersari arial al pro procee ceedin ding, g, whe wheth ther  er   judicial or quasi-judicial. The confidentiality of the mediation process is for the  purpose of promoting candor of parties and mediators to foster a prompt, econom eco nomic ical al and ami amicab cable le res resolu olutio tion n of dis disput putes es.. Thi Thiss sho should uld als also o be tru truee in Katarungang Pambarangay, otherwise conflicting parties will not be candid in the  process of conciliation for fear of being imputed later on of a crime for utterances they have made during the process or for fear that what they have revealed would  be used against them. them. Moreov Mor eover er,, in con concil cilia iatio tion n pro proce ceedi edings ngs bef before ore the Dep Depart artmen mentt of Lab Labor or,, information and statement during said conciliation proceedings are prohibited to  be used in evidence, evidence, to wit: Art. 233. Privi Privileged leged Comm Communica unication. tion. Inform Information ation and sta statemen tements ts madee at con mad concil ciliat iation ion pro proce ceedi edings ngs sha shall ll be tre treat ated ed as pri privil vilege eged d com commun unic icat atiion and shall hall no nott be use sed d as ev eviiden ence ce in the the 4

 An Ac To Instutonalize The Use Of An Alernatve Dispue Resoluton Sysem In The Philippines And To Esablish The Oce For Alernatve Dispue Resoluton, And For Oher Purposes 5  Sec. 53, ADR

 Motion to Quash Criminal Criminal Case 2626

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Commission. Conciliators and similar officials shall not testify in any court or body regarding any matters taken up at conciliation  proceedings conducted conducted by them.6 In Nissan In  Nissan Motors Philippines, Inc. v. Secre Secretary tary of Labor 7, the court pointedly disallowed the award made by the public respondent Secretary since the award was bas based ed on the inf inform ormati ation on NCM NCMB B Ad Admin minist istrat rator or Ola Olalia lia sec secure ured d fro from m the confidential position given him by the company during conciliation. The same doctrine was reiterated in the case of Pentagon of  Pentagon Steel Corp. v. Court of Appeals,8 the court said: “We agr “We agree ee with the peti petitio tioner ner,, but for a dif differ ferent ent reason. reason. The correct reason for the CA’s error in considering the actions and agreements during the conciliation proceedings before the labor  arbi arbite terr is Ar Arti ticl clee 23 233 3 of th thee La Labo borr Co Code de wh whic ich h stat states es that that ‘[i]nforma ‘[i]n formation tion and stat statemen ements ts made at conc conciliat iliation ion proce proceeding edingss shall be treated as privileged communication and shall not be used as evidence in the Commission. Conciliators and ssimilar imilar officials officials shall not testify in any court or body regarding any matters taken up at conciliation proceedings conducted by them.’ xxx In the present case, we find that the CA did indeed consider the statements the parties made during conciliation; thus, the CA erred  by considering excluded materials in arriving at its conclusion. x x x” The court further discussed on the two-fold justification for the exclusionary rule, thus: “First, since the law favors the settlement of controversies out of court, a  person is entitled to “buy his or her peace” without danger of being  prejudiced in case his or her efforts fail; hence, any communication made toward that end will be regarded as privileged. Indeed, if every offer to buy  peace could would be used evidenceand against a person litigation who presents it, result, many settlements beas prevented unnecessary would since no prudent person would dare offer or entertain a compromise if his or her her comp compro romi mise se po posi siti tion on coul could d be ex expl ploi oite ted d as a conf confes essi sion on of  weakness. xxxx Finally, in mediation proceedings before the Philippine Mediation Center and the Judicial Dispute Resolution, any and all matters discussed or communications made, including requests for mediation and documents presented during the said  proceedings shall be privileged and confidential, and the same shall be inadmissible as evidence for any purpose in any other proceedings.9 6

 Labor Code of he Philippines.  G.R. Nos. 158190-91, June 21, 2006 8  G.R. No. 174141, June 26, 2009. 7

9

 A·M.

No, 11-1-6-SC-PHILJA, CONSOLIDATED AND REVISED GUIDELINES TO  Motion to Quash Criminal Criminal Case 2626

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To succinctly put, the prominent spirit of the law is to allow the parties an avenue to discuss their issues and difference without fear of criminal prosecution in order for them to settle their dispute outside of the courts. Otherwise, Otherwise, the goal of  an amicable settlement outside of courts, for which the law was created, would be a mere illusion, and the law a futile legislation. Therefore, the utterances made therein is privileged and inadmissible in court. 4.

The warrant of arrest is void ab initio, and should  be re reca callle led d, be beccau ause se the Co Cour urtt di did d no nott mak akee a  personal determination of probable cause but  instead merely adopted the findings in the resolution issued by the investigating officer.

With the above discussion, it is evident that the Court did not make a personal evaluation of the records of the case to determine whether probable cause exists to  justify the issuance of the assailed warrant of arrest. The Court could have known that the Certification issued by the Barangay was issued for accused Jenalyn De Guzman and Sheila Seit only, and not for the other two accused, Jocelyn De Guzman and Alma Sienes. The said certification was also issued for a different compla com plaint int/in /incid cident ent fil filed ed by Pri Privat vatee com compl plain ainant ant Lin Linda da Gen Gentil tilizo izo bef before ore the Barangay. Moreover, the minutes of the mediation proceedings dated September  10, 2016, which the Prosecution relied its finding on do not show the alleged defamatory utterances made by accused Sheila Seit. With respect respect to the minutes of  the mediation proceedings dated September 29, 2016, which was used as the basis for the charged against accused Jenalyn De Guzman, Jocelyn De Guzman, and Alma Sienes, it is an incomplete record of what really transpired during the said  proceedings. Thus, Thus, it is erroneous to conclude that what what was written in the minutes minutes are defamatory defamatory in natur naturee because not only were they made as an answ answer er to the mediator’s query, but were also uttered in a barangay reconciliation proceedings, thus considered privileged and confidential. The Court could could hav havee kno known wn that the there re wa wass ind indeed eed no bas basis is for the crim crimee charged against the accused and would have not issued the warrant of arrest had he made a more than cursory examination of the records of the case. It only goes to show that there was no personal examination of the records done by the Court as required by law. Instead, the warrant of arrest was perfunctorily issued based on the certification of the prosecutor that probable cause exists, in violation of the constitutional provision that no warrant shall issue except upon probable cause to  be determined personally personally by the judge. 

IMPLEMENT THE EXPANDED COVERAGE OF COURTANNEXED MEDIATION (CAM) AND JUDICIAL DISPUTE RESOLUTION (JDR), January 11, 2011.  Motion to Quash Criminal Criminal Case 2626

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In the case of Mayor Bai Unggie D. Abdula and Odin Abdula vs. Hon. Japal M. Guiani10, the Supreme Court held, thus:  “Alhough he prosecuor enjoys he legal presumpton of regulariy in he performance of his ocial d utes, which in urn gives his repor he presumpton of accuracy, nohing less han he fundamenal law of he land commands he judge o personally deermine probable cause in he iss issua uance nce of wa warr rran ans s of arr arres es. . A judge judge fa fails ils in his his co cons nst tuto utonal nally ly mandaed duy if he relies merely on he certcaton or repor of he investgatng ocer. ocer. xxxx The circumsances hus require ha responden look beyond he bare certcaton certcato n of he investgatn investgatng g prosecu prosecuor or and examine he documens documens suppor sup portng tng he prose prosecu cuor' or'ss deerm deermina inato ton n of proba probable ble ca cause use.. The The inordinae inordina e hase ha aended he issuance of he warran of arres and responden's own admission are circumsances ha end o belie any preense of he fulllmen of his duy. Clearly, responden judge, by merely satng ha he had no reason o doub doub h he e va vali lidi diy y of h he e cert certc cat aton on made made by h he e inve invest stg gat atng ng prosecuor has abdicaed his duy under he Constuton o deermine on his own he issue of probable cause before issuing a warran of  arres. Consequenly, he warran of arres should be declared null and void.”(underscoring supplied) 5. The case case should should be reinves reinvestga tgaed ed because because he he evidence evidence relied relied upon by he Prosecuton are grossly insucien o warran probable cause. As has been been hig highli hligh ghed ed abo above ve,, he min minue uess of he mediat mediaton on pr proce oceedi edings ngs by which which he Prosec Pro secuto uton n based based is nding ndingss of pr proba obable ble cause cause are uerly uerly incomp incomple lee e and als also o con consid sidere ered d privileged and condental in naure. I could no possibly engender a well-founded belief in a reasonable mind ha a crime has been commied and he persons charged are probably guily hereof. Such reinvestgaton would no only lessen he dockes, bu also proec he innocen from being subjeced o he rouble of a public rial.

CONCLUSION

In vie view w of all the for forego egoing ing,, accus accused ed Jo Jocel celyn yn De Guz Guzma man, n, Jen Jenaly alyn n De Guzman, and Alma Sienes submit that the alleged utterances they made do not constitute the crime of grave slander nor is there any probable cause to indict them for the same. On the other hand, accused Sheila Seit submits that she never made such utterance as alleged by the complainant and information. As such, there is no offens off ensee to spe speak ak of and con conseq sequen uently tly,, the ac accus cused ed can cannot not be cha charg rged ed of gra grave ve slander. P R A Y E R 

WHEREFORE, it view of all the foregoing, it is most respectfully prayed

that the information be quashed, the warrant of arrest be recalled, and/or the case 10

 G.R. No. 118821, 18 February 2000.

 Motion to Quash Criminal Criminal Case 2626

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 be reinvestigated reinvestigated to determine probable probable cause. Other relief just and equitable are likewise prayed for. for. Dumaguete City, Philippines, August 16, 2016.

GRACELYN E. BELLINGAN Roll of Attorneys No. 65133; PTR No. 0462961 (06/23/16) Sibulan, Negros Or. IBP Receipt No. 1042038 (06/13/16); Pasig City MCLE Exempt, Admitted to the Bar on June 17, 2016, MCLE Board Order No. 1, s.2008 Cel. No. 09054028121; Email: [email protected] G/F Villareal Hall, Silliman University Dumaguete City

LESLIE JOY L. CUEVAS Roll of Attorneys No. 65301; PTR No. 1378930, 7-18-16, Dumaguete City.

IBP Lifetime No. 1042628, 6-15-16 MCLE Exempt, Admitted to the Bar on June 17, 2016, MCLE Board Order No. 1, s.2008 nd 2  Floor DRBI Building, San Jose St., Dumaguete City

NOTICE OF HEARING

Greeting: Please take notice that the foregoing Motion will be submitted for  the Court’s consideration without issue.

COPY FURNISHED:

Hon. Ronald Tenaja Prosecutor II   PPO Dumaguete City

 Motion to Quash Criminal Criminal Case 2626

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