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Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION


REGIONAL TRIAL COURT
Branch 282, Valenzuela City

PEOPLE OF THE PHILIPPINES,

-versus- Crim. Case No. 1874-V-18


For: Violation of Sec. 12, Art. II of
R.A. 9165
PAULO MOYA y FRIAS, ERWIN
RIMONTE y SORDILLA, ROMEO
MOYA y LANTACE, ANGELO
VALDEZ y ENCARNACION and
ALWIN CAAGBAY y CANDA,
Accused.
x- - - - - - - - - - - - - - - - - - - - -x

-versus- Crim. Case No. 1875-V-18


For: Violation of Sec. 15, Art. II of
PAULO MOYA y FRIAS, ROMEO R.A. 9165
MOYA y LANTACE, ANGELO
VALDEZ y ENCARNACION and
ALWIN CAAGBAY y CANDA,
Accused.
x- - - - - - - - - - - - - - - - - - - - -x

MOTION TO CONVERT PERIOD OF DETENTION OF ACCUSED


AS EQUIVALENT TO THEIR REHABILITATION

The above-named accused, assisted by the Public Attorney’s Office,


unto this Honorable Court, most respectfully file this motion and aver that:

1. During their arraignment all of the above-named accused pleaded


guilty for violation of Sections 12 and 15 12, Article II of R.A. 9165.
Accordingly, in Criminal Case No. 1874-V-18, the Honorable Court
sentenced them to suffer the penalty of imprisonment for 1 year, as
well as to pay a fine of P10,000 with subsidiary imprisonment due to
insolvency. With respect to Criminal Case No. 1875-V-18, the
Honorable Court sentenced them to rehabilitation for six (6) months
in a government center in accordance with the rehabilitation
program of the city government of Valenzuela and/or the Mega Drug
Treatment and Rehabilitation Center in Nueva Ecija; and

2. Based on the drug test report and the medical certificate of the
above-named accused, which were issued by the Valenzuela Medical
Center, they were found negative for methamphetamine and
tetrahydrocannabinol during the time they were examined. They
were recommended to be enrolled in the community after care
program of the Valenzuela Anti-Drug Abuse Council (VCADAC). In
this connection, in lieu of requiring the accused to undergo
rehabilitation, as hereinabove mentioned, the defense implores the
Honorable Court to consider their period of detention since 19
October 2018 as equivalent to their rehabilitation in addition to the
community wellness program of the Valenzuela Anti-Drug Abuse
Counseil (VCADAC) which they have to undergo. This is understood
to be subject to the proviso that their minimum period of detention
is six (6) months.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed


before this Honorable Court to grant this instant motion.

Other relief and remedies, just and equitable, are likewise prayed
for.

Valenzuela City, Metro Manila, 1 March 2019.

PUBLIC ATTORNEY’S OFFICE


VALENZUELA DISTRICT OFFICE
1st Floor, Metropolitan Trial Court Bldg.
Justice Hall Compound, C.J. Santos St., Poblacion II,
Malinta, Valenzuela City

Through:

ATTY. RAFAEL D. PANGILINAN


Public Attorney II
Roll No. 64684
IBP OR No. 035862 dated 8/1/18 / CALMANA
MCLE Compliance No. VI - 0006876 dated 3/20/18

Copy furnished and Notice of Hearing:


Atty. Aireen M. Cacho-Jayme
Branch Clerk of Court
Regional Trial Court, Branch 282, Valenzuela City

ACP Mary Jenneane M. Yambot


Office of the City Prosecutor
Valenzuela City
Greetings! Please note that the undersigned will submit the
foregoing answer with motion to dismiss for the kind consideration and
approval of the Honorable Court on 8 March 2019 at 8:30 in the
morning.

ATTY. RAFAEL D. PANGILINAN