REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

Branch 275
Las Pinas City, Philippines

PEOPLE OF THE PHILIPPINES,

Plaintiff

-versus-

Crim.CaseNo.01-0005
For: Murder

JUNJUN DACUBO
Accused.
x---------------------------------------------------------/

INFORMATION
The undersigned Assistant Provincial Prosecutor accuses JUNJUN DACUBO of the crime of Murder under the
Revised Penal Code, committed as follows:

That on or about 24th day of October 2000, in the City of Las Pias, Philippines and within the
jurisdiction of this Honorable Court, the above-named [appellant], without justifiable motive with intent to
kill and by means of treachery, did then and there willfully, unlawfully and feloniously attack, assault, and
shoot with a gun the head of one ROGELIO GONZALES Y FACTOR thereby inflicting mortal gunshot
wound to the said victim which directly caused his death. 4

CONTRARY TO LAW.
Raymond Romulo
Assistant Provincial Prosecutor

CERTIFICATION
I HEREBY CERTIFY that a Preliminary Investigation in this case has been conducted by me in accordance with
law; the I have examined the complainant and his witnesses; that there is reasonable ground to believe that a
crime has been committed and that the accused is probably guilty thereof; that the accused was informed of the
complaint and of the evidence submitted against him and was given an opportunity to submit controverting
evidence; and that the filing of this Information is with the prior authority and approval of the City Prosecutor.

Raymond Romulo
Assistant Provincial Prosecutor

SUBSCRIBED and SWORN TO BEFORE ME this 14 th of December 2000 at the City of Las Pinas,
Philippines.

Alejandro Salas
Chief State Prosecutor

Witnesses:
Miguel LabraMatag-ob, Las Pinas City
Eric Lor---- Matag-ob, Las Pinas City
NO BAIL RECOMMENDED.

REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
Branch 275
Las Pinas City, Philippines

PEOPLE OF THE PHILIPPINES,

Plaintiff

-versus-

Crim.CaseNo.01-0005
For: Murder

JUNJUN DACUBO
Accused.
x---------------------------------------------------------/

MOTION TO SUSPEND ARRAIGNMENT

and / or
DEFER PROCEEDINGS
Accused, by the undersigned counsel, and unto this Honorable Court, alleges:
1.

He is suffering from and unsound mental condition which effectively renders him unable to fully
understand the charge against him and to plead intelligently thereto. Attached is the Certificate of
Confinement issued by Perpetual Help Hospital and a Certificate issued by Dr. Mill Tan-Ty herein
referred to as Exhibits 1 and 2 respectively.
WHEREFORE, in view of all the foregoing, it is respectfully prayed that an Order be issued suspending

the arraignment of the accused.

Las Pinas City, Philippines.
January 10, 2001.
Mark Allan Milan
Counsel for the Accused

NOTICE OF HEARING
Raymond Romulo
Assistant Provincial Prosecutor
Las Pinas City, Philippines

Please be notified that accused is submitting the motion for the consideration and approval of the
Honorable Court on February 24, 2001.
Mark Allan Milan
Counsel for the Accused
PTR NO.10290
IBP NO. 12345
ROLL OF ATTORNEY NO. 22189
MCLE COMPLIANCE: 2010
Las Pinas City Philippines

Copy furnished:

Raymond Romulo
Assistant Provincial Prosecutor
Las Pinas City, Philippines

REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
Branch 275
Las Pinas City, Philippines

PEOPLE OF THE PHILIPPINES,

Plaintiff

-versus-

Crim.CaseNo.01-0005
For: Murder

JUNJUN DACUBO
Accused.
x---------------------------------------------------------/

MOTION FOR BAIL

Accused, by undersigned counsel, and unto this Honorable Court, alleges:
1. The prosecution has filed an Information against the accused alleging that they have found probable
cause that the accused committed the crime of murder and recommended no bail.
2. Accused submits that the evidence of guilt against him is not strong, thus, entitling him to bail.
WHEREFORE, in view of all the foregoing, accused prays that after hearing, he be released on bail and
this Honorable Court fixed the amount thereof.
Las Pinas City, Philippines.
February 28, 2001.

Mark Allan Milan

Counsel for the Accused
PTR NO.10290
IBP NO. 12345
ROLL OF ATTORNEY NO. 22189
MCLE COMPLIANCE: 2010
Las Pinas City Philippines

NOTICE OF HEARING
Raymond Romulo
Assistant Provincial Prosecutor
Las Pinas City, Philippines

Please be notified that accused is submitting the motion for the consideration and approval of the
Honorable Court on March 20, 2001.

Mark Allan Milan

Counsel for the Accused
PTR NO.10290
IBP NO. 12345
ROLL OF ATTORNEY NO. 22189
MCLE COMPLIANCE: 2010
Las Pinas City Philippines

Copy furnished:
Raymond Romulo
Assistant Provincial Prosecutor
Las Pinas City, Philippines

REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT
Branch 275
Las Pinas City, Philippines

PEOPLE OF THE PHILIPPINES,

Plaintiff

-versus-

Crim.CaseNo.01-0005
For: Murder

JUNJUN DACUBO
Accused.
x---------------------------------------------------------/

MOTION FOR DETERMINATION OF PROBABLE CAUSE

and SUSPEND ISSUANCE OF WARRANT OF ARREST
Accused, by the undersigned counsel, and unto this Honorable Court, alleges:
The prosecution has filed an Information against the accused alleging that they have found probable
cause that the accused committed the crime of murder.
Accused submits that there is no sufficient evidence to engender a well founded belief that the accused
committed the crime of murder.The testimony of Rolando Gonzales Y Factor based on the affidavit executed by
him before the Office of the Prosecution, as its lone witness clearly shows absence of participation of herein
accused. He categorically admitted that at the time of the shooting incident, he was looking at the ground, as he
was then sweeping inside their house. That Rolando neither witnessed how the deceased was fired by the gun
nor did he see the act of shooting such deceased. Rolando cannot even describe the firearm allegedly used in
killing the victim, which proved that he was not in the crime scene and he did not actually witness the shooting.
By this, it is clear that the prosecution has failed to establish a case against accused.
WHEREFORE, in view of all the foregoing, accused prays that:
1. An Order be issued requiring the prosecution to elevate the entire records of the Preliminary
Investigation of the case.
2. In the meantime that this Court considers this motion, to suspend the issuance of the Warrant of Arrest
against the accused.
3. After an examination of the records is made, an order be issued finding no probable cause against the
accused and that the case be dismissed.
Las Pinas City, Philippines.
March 25, 2001

NOTICE OF HEARING
Raymond Romulo
Assistant Provincial Prosecutor
Las Pinas City, Philippines

Please be notified that accused is submitting the motion for the consideration and approval of the
Honorable Court on April 12, 2001.

Mark Allan Milan

Counsel for the Accused
PTR NO.10290
IBP NO. 12345
ROLL OF ATTORNEY NO. 22189
MCLE COMPLIANCE: 2010
Las Pinas City Philippines

Copy furnished:

Raymond Romulo
Assistant Provincial Prosecutor
Las Pinas City, Philippines