REPUBLIC OF THE PHILIPPINES

THIRD JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 50
GUAGUA, PAMPANGA

PEOPLE OF THE PHILIPPINES,

Plaintiff, Crim. Case No. xxxxxxxx and
xxxxxxxxxxxx
--- versus -- For: VIOLATION OF ARTICLE 2,
SECTION 5 and 11 OF R.A. 9165

xxxxxxxxxxxxxxxxxxxxx,
Accused,
x--------------------------------------------- x

MOTION FOR APPLICATION FOR PROBATION

The accused, xxxxxxxxxxxxxxxxxxxxxxx, through the Public Attorney’s

Office (PAO), and to this Honorable Court most respectfully states that:

1. Accused availed the benefits of plea bargaining under A.M. 18-03-16-SC:

Adoption of the Plea Bargaining Framework in Drugs Cases.

2. On August 2, 2019, accused was re-arraigned for two counts of violation of

Section 12 of Republic Act 9165, on the same date, the Honorable Court
promulgated its Judgment in said cases finding the accused guilty beyond
reasonable doubt and was sentenced to suffer the penalty of 6 months
and 1 day to 4 years and to pay a fine of P10,000 in each case. Said
sentence shall also be served simultaneously. Accused is also hereby
credited of his preventive detention. Attached herein as Annex “A” to “A-
1” is a copy of the Judgment dated August 2, 2019.

3. In view of the foregoing judgment, he wishes to avail the benefits under

Presidential Decree No. 968 (Probation Law of 1976), as amended;

4. He is not among those disqualified offenders enumerated under Section 9

of Presidential Decree No. 968, as amended;

5. The crime for which the Accused/Applicant is convicted is not an offense

against the security of the State;

6. Accused has not been on probation under the provisions of the Probation
Law;

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 7. Accused was not previously convicted by final judgment of any offense
punished by imprisonment of more than one (1) month and one (1) day or
a fine of more than P200.00;

8. Accused is sincerely remorseful and penitent of his present offense and, if

granted probation, is willing to undergo supervision under such terms and
conditions that may be imposed by the Honorable Court.

9. He further undertakes to faithfully and religiously comply with the

conditions of the probation as provided for under P.D. 968 (Probation Law
of 1976) or as may be ordered by the Honorable Court should this
application for probation be granted.

PRAYER
WHEREFORE, after due notice and hearing, it is most respectfully prayed
of this Honorable Court to suspend the execution of the sentence of accused in
the above-entitled case and place her under probation.

Other reliefs which are just and equitable in the premises are also prayed.

Guagua, Pampanga, August 2, 2019.

NOTICE OF HEARING

The Branch Clerk of Court

Regional Trial Court
Branch 50
Guagua, Pampanga

GREETINGS:

Please submit the foregoing Motion for the kind consideration and
approval of the Honorable Court immediately upon receipt hereof.

xxxxxxxxxxxxxxxxxxxxxxxxxx
Public Attorney II

Copy furnished by Personal Delivery:

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xxxxxxxxxxxxxxxxxxxxxxxxxxxxx
Office of the Provincial Prosecutor
City of San Fernando, Pampanga

PAMPANGA PAROLE AND

PROBATION OFFICE
310 and 312 Hall of Justice Bldg.,
Capitol Compound, CSFP

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