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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


NATIONAL JUDICIAL REGION XVIII
Guihulngan City, Negros Oriental, Branch __,

People of the Philippines, Criminal Case No. 9111111


Plaintif

~ versus ~ For: HOMICIDE

SPO1 Severino Tabayacyac, et. al.


Accused

x-------------------------------------------------x

URGENT MOTION
FOR ISSUANCE OF HOLD DEPARTURE ORDER

COMES NOW, the plaintiff, by the undersigned private counsel, with the
conformity of the public prosecutor and unto this Honorable Court,
respectfully moves for the issuance of a Hold Departure Order (HDO) against
the accused, and alleges that:

1. The accused is currently employed by the Philippine National Police


(PNP). In light of this ongoing case, a Memorandum was issued to the
accused stating that the he is reinstated to Cotabato City until the
resolution of this case. Attached hereto is a copy of a Memorandum and
marked as Annex A;
2. The Memorandum was issued before the accused has submitted a copy
of his bail bond amounting to FIVE HUNDRED THOUSAND PESOS
(P500,000.00). Attached hereto is a copy of the above-mentioned bail
bond marked as Annex B;
3. In view of the above mentioned circumstances, A Watch List Order
(WLO) against the accused has been issued by the Department of
Justice (DOJ) upon application of the plaintiff attached and marked
hereto as Annex C;
4. Preventing the accused fromleaving the country is proper considering
that the crime charged against him is a serious offense;
5. All precautions should be observed to ensure proper dispensation of
justice.

WHEREFORE, premises considered, it is respectfully prayed that a Hold


Departure Order be immediately issues against the accused.

Guihulngan City, Negros Oriental, Philippines, November 5, 2016.

ATTY. JADE A. LORENZO


Private Counsel for the Plaintiff
PTR No. __________; (date); Manila City
IBP Lifetime No. __________; (date)
Address:
Mobile:
Email:

ATTY. ANDREA MARIA THERESE Y. MAURICIO


Private Counsel for the Plaintiff
PTR No. __________; (date); Manila City
IBP Lifetime No. __________; (date)
Address:
Mobile:
Email:

CONFORME:

LEILA MARIE V. TRILLANES


Assistant City Prosecutor

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NOTICE OF HEARING

SPO1 SEVERINO TABAYACYAC


Lot 9, Block 10, Lipton Street, City of Guihulngan

Greetings:

Please be informed that the foregoing Motion for Extension of Time to


file Counter Affidavit is requested to be submitted for the consideration of the
Honorable Investigating Prosecutor immediately upon receipt hereof.

ATTY. JADE A. LORENZO

Private Counsel for the Plaintiff

ATTY. ANDREA MARIA THERESE Y. MAURICIO

Private Counsel for the Plaintiff

EXPLANATION

Copies of the foregoing Motion for Issuance of Hold Departure Order


were served on the Complainant by registered mail since personal service is

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not practicable because of time constraints and the distance between the
office of the undersigned counsel and the residence of the Complainant.

ATTY. JADE A. LORENZO

Private Counsel for the Plaintiff

ATTY. ANDREA MARIA THERESE Y. MAURICIO

Private Counsel for the Plaintiff