Republic of the Philippines

REGIONAL TRIAL COURT

6th JUDICIAL REGION
BRANCH 31
Iloilo City, Iloilo

PEOPLE OF THE PHILIPPINES,

Complainant,
Criminal Case No. 30003
- versus - For: VIOL OF SECTION 93
OF R.A 10654

LUCIA DOGGO and

SCRAPI PEUPER,
Accused.
x ------------------------------------------ x

OMNIBUS MOTION FOR PRELIMINARY INVESTIGATION W/

MOTION TO DEFER ARRAIGNMENT & TO SUSPEND
PROCEEDINGS

COMES NOW, the accused, through counsel, in the above entitled-

cases unto this Honorable Court, most respectfully avers:

1. That the instant case was filed by virtue of an Inquest

Proceedings conducted by Inquest Prosecutor Steven
Gerrard on January 28, 2015;

2. That both the herein accused only learned of the filing of the
information after they received a Subpoena on May 21, 2016
issued by this Honorable Court on May 08, 2016
commanding them to appear on June 03, 2016 for the
scheduled arraignment of this case ;

3. That it was only on May 22, 2016, that the accused engaged
the services of the undersigned counsel ;

4. That the herein accused failed to submit any counter

affidavit or any controverting evidence on their behalf;
 5. That both the accused believed that if they will be given an
opportunity to answer the charges against them, the
resolution could have been different;

6. That the accused most respectfully prays that a preliminary

investigation for the instant case be conducted before the
Office of the City Prosecutor of Iloilo City, Iloilo ;

7. That this motion is not intended for delay but solely upon
above-mentioned grounds.

WHEREFORE, premises considered, and in the interest of

substantial justice it is humbly prayed that the instant Motion be granted and
the records of the instant case be transmitted to the Office of the City
Prosecutor of Iloilo City for the conduct of Preliminary Investigation.
Movant further prays for the deferment of the arraignment and for the
suspension of proceedings pending resolution of preliminary investigation.

Other reliefs be granted as shall be deemed just and equitable in the

premises
May 26, 2016. Iloilo City, Philippines

RESPECTFULLY SUBMITTED.

THE LAW FIRM OF MARIA FERRER

(Counsel of the Accused)
Suite 221 JD Bldg., Arevalo St.,
cor. Gen Luna St., Iloilo City
Tel No. (033) 253-0454

By:

JANET J. MAKSON
Roll of Attorney No. 7000 April 27,2010
PTR OR No. 8713641/11/2011
IBP OR No. 1014806 01/05/11 Iloilo City Chapter
MCLE COMPLIANCE No. Exempt
Email add: janetmacman@gmail.com
 NOTICE AND REQUEST FOR HEARING

The Branch Clerk of Court

RTC BRANCH 31
Iloilo City

Sir/Maam :

Please calendar the foregoing Motion for hearing on May 10, 2016 at
10:30 o’clock in the morning or at the earliest possible calendar of this
Honorable Court, sans personal appearance of undersigned counsel.

ATTY. JANET J. MAKSON

Copy furnished:

ATTY. STEVEN GERRARD

Associate Prosecution Attorney II
City Prosecutor’s Office
Iloilo City Iloilo