REPUBLIC OF THE PHILIPPINES

8TH JUDICIAL REGION

Municipal Trial Court
Branch 6
Tacloban City

PEOPLE OF THE PHILIPPINES, Criminal Case No. 2018-456

Plaintiff, For: Violation of Batas
Pambansa Blg. 22

-versus-

RACHEL CHU
Accused,

X-------------------------------------X

MOTION FOR LEAVE TO FILE DEMURRER TO EVIDENCE

The accused, Rachel Chu, by the undersigned counsel and unto

this Honorable Court, most respectfully states:

1. That the prosecution already rested its case;

2. That the Honorable Court had already made a ruling on the
prosecution’s formal offer of evidence copy of which was
received by the accused on June 12, 2018;
3. That the prosecution’s evidence is inherently weak, insufficient
and unsubstantiated to prove the guilt of the accused beyond
reasonable doubt;
4. That with all due respect, it is necessary for the defense to be
allowed by this Honorable Court to file his Demurrer to Evidence
with LEAVE OF COURT to be able to point out in details the
weakness of the prosecution’s evidence necessitating the
dismissal of this case.

WHEREFORE, it is most respectfully prayed of this Honorable

Court that the instant motion be granted, allowing herein accused thru
counsel to file with LEAVE OF COURT DEMURRER TO EVIDENCE.

Other reliefs and remedies available under the premises are likewise
prayed for.

1|Motion for Leave

 Respectfully submitted, Tacloban City, Philippines, 13th of June,
2018.

Atty. Nicholas Young

Counsel for the Accused
Molina& Partners Law Offices
XYZ Bldg. Real St., Tacloban City
Attys. Roll No. 12345/ 1-1-06
PTR No. 12345/1-03-18, Tacloban City
IBP O.R. NO. 7654321/01-01-18,Tacloban Chapter
MCLE COMPLIANCE NO.: V-0001111/01-01-2018
Phone No: 09161234567

NOTICE OF HEARING

To the Branch Clerk of Court

Assistant City Prosecutor
Regional Trial Court
Tacloban City, Branch 6

Please submit the foregoing Motion to the Court for its

consideration and approval immediately upon receipt hereof and kindly
include the same in the Court’s calendar for hearing on the 15th day of
June, 2018 at 8:30 in the morning.

Atty. Nicholas Young

Copy furnished thru personal service:

Astrid Leong
Assistant City Prosecutor
Office of the City Prosecutor
Tacloban City

2|Motion for Leave