Republic of the Philippines

MUNICIPAL TRIAL COURT

Branch IX
General City

THE PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- CRIM. CASE NO. 52225-1

JOE MENDOZA,
Accused.
X - - - - - - - X

MOTION FOR TRANSFER AND CONSOLIDATION

The ACCUSED, before this Honorable Court most respectfully avers:

THAT-----

1. The accused is also charged with offenses of three (3) “Estafa”

before the Honorable Municipal Trial CORT, Branch 3, General
City that have the lower Criminal Case Numbers such as: 76143-
3, 96344-3 and 8776346-3;

2. In the said cases the same accused is involved with same

criminal offenses as charged, same place and type of
transactions, involve the same question of law and facts as in
the instant case although with different private complainants
but investigated by the same Assistant City Prosecutor
Money Pukyaw;

3. The accused is going to attend the scheduled arraignments

and pre-trial conferences in the aforementioned three (3)
criminal cases on October 18, 2019 at 8:30 o’clock in the
Motion For Consolidation
Crim. Case No. 57745-1
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morning which date and time also coincide with the

scheduled arraignment of the accused in the instant case.

4. To save time, effort, expenses and to have all

cases intimately related acted upon by one Court to avoid
the possibility of conflicting decisions being rendered, the
Accused is respectfully moving for the transfer and
consolidation of the instant case with the three (3) cases
pending before the Honorable Municipal Trial Court In
Cities, Branch 3, General City that have the lower Criminal
Case Numbers such as: 95043-3, 96344-3 and 86346-3.

WHEREFORE, it is most respectfully prayed that the instant case

be transferred and consolidated with the three (3) criminal cases
pending before the Honorable Municipal Trial Court In Cities,
Branch 3, General Santos City that have the lower Criminal Case
Numbers such as 4643-3, 76344-3 and 86346-3.

This 3rd the day of October, 2019 here at General Santos

City, Philippines.

MOST RESPECTFULLY SUBMITTED.

JOE DUGAS
Accused