Republic of the Philippines

Metropolitan Trial Court in Cities

Branch 1
First Judicial Region
Baguio City

PEOPLE OF THE PHILIPPINES, Crim. Case Nos. 2600

- versus – For: Falsification of
PEDRO JUAN Commercial Document

Accused.
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APPLICATION FOR PROBATION

ACCUSED, through the undersigned counsel and unto this

Honorable Court, most respectfully applies for probation under the
provisions of Presidential Decree No. 968 as amended and states that:

1. On 20 September 2019, accused was convicted of the crime of

Falsification of Commercial Document and was sentenced to
suffer one (1) year of prision correccional as minimum to four (4)
years and two (2) months of prision correccional as maximum
and to pay a fine of P3,000.00, with subsidiary imprisonment in
case of insolvency or non-payment;

2. The crime for which the accused was convicted is not an offense
against national security or public order;

3. Accused has not been previously convicted by final judgment of

any offense punishable by imprisonment of not less than one
month and one day and/or fine of not less than two hundred
pesos;

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 4. Accused has not been once placed on probation under the
provisions of Presidential Decree No. 968, otherwise known as
the Probation Law of 1976, as amended;

5. Accused has all the qualifications and none of the

disqualifications to avail of the benefits of the Probation Law.

WHEREFORE, premises considered, it is most respectfully prayed

of this Honorable Court that the Application for Probation be referred
to the Parole and Probation Officer of Baguio City for the requisite
post-sentence investigation and thereafter, the application for
probation be approved.

Other reliefs just and equitable in the premises are likewise sought.

Baguio City, Philippines. September 26, 2019.

ATTY. RED HORSE

Counsel for the Accused

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 NOTICE OF HEARING

THE BRANCH CLERK OF COURT

MTCC - Branch 1
Baguio City

Greetings!

Please submit the foregoing motion to the Honorable Court on

October 2, 2019 at 11:00 in the morning for its favorable consideration
and approval.

ATTY. RED HORSE

Copy furnished by personal service:

PROSECUTOR EXTRA STRONG

Office of the City Prosecutor, Baguio City

PAROLE AND PROBATION OFFICE

Baguio City

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