Republic of the Philippines

REGIONAL TRIAL COURT

____Judicial Region
Branch __, Baguio City

REIGN M. CAMLAS, CASE NO. ________

Complainant,

- versus - FOR: LIBEL

BRIXTON OCHOA and

ESTER SANCHEZ,
Respondents.
x---------------------x

MOTION FOR LEAVE OF COURT to file

DEMURRER TO THE EVIDENCE

Comes Now, Accused, through counsel, respectfully states:

1. That the prosecution has presented its witnesses and has formally
offered its evidence;

2. That the admissibility of exhibits so offered had been resolved and

was received by the undersigned counsel.

3. That the accused seeks leave of court to file a Demurrer to the

Evidence on the ground that the evidence presented by the
prosecution is not sufficient to warrant a conviction of the guilt of the
accused beyond reasonable doubt as it failed to prove that he is the
person subject of the libelous article or remark, and that it his
reputation which was targeted because there were actually two (2)
Palangdao Buildings located in Baguio City and there were several
proprietor in both buildings who owns and operates a business in the
line of cosmetics.
4. That in the event the said demurrer to evidence will not be given
due course by this Honorable Court, the accused nevertheless be
allowed to present evidence for his defense.

PRAYER

WHEREFORE, foregoing premises considered and in the interest

of justice, it is most respectfully prayed to this Honorable Court to grant
herein Motion, with prior leave of court, to file demurrer to evidence
and to admit said demurrer to evidence, which is hereto attached,
once the motion was granted.

Other reliefs and remedies available under the premises are

likewise prayed for.

Baguio City, Philippines, November___, 2019.

ATTY. RENZ KHO

Counsel for the Accused
#20 Session Road, Baguio City
PTR No. 98764/Baguio City/12-31-2019
Roll of Atty. No. 78652
IBP Lifetime Membership No. 78653
MCLE Compliance No. 30833

NOTICE

Atty.________________
The Clerk of Court
RTC Branch___,
Baguip City

GREETINGS:

Please submit the forgoing MOTION to the Honorable Court for

its consideration, immediately upon receipt hereof.
Baguio City, Philippines, November__, 2019.

ATTY: RENZ KHO

Counsel for the Accused

Copy Furnished:
Atty. Vine Perocho
Prosecutors Office
Baguio City