Republic of the Philippines

National Capital Judicial Region

Regional Trial Court
Branch 201
Laguna

PEOPLE OF THE
PHILIPPINES,

Plaintiff,
Criminal Case No. XXX
-versus- For: Violation of Republic Act
No. 9262

AAA,

Respondent.
x----------------------------------------x

OMNIBUS MOTION
(Motion for Issuance of Temporary Protection Order and Motion for
Issuance of Hold Departure Order)

Private complainant, with permission of the Honorable Public

Prosecutor, through the undersigned counsel, respectfully states:

1. On April 2, 2010, an Information for Violation of Republic

Act No. 9262 also known as "Anti-Violence Against Women and Their
Children Act of 2004" was filed against AAA, for the physical,
psychological and emotional abuse suffered by the Private Complainant
and their minor child BBB.
 ALLEGATIONS IN SUPPORT OF THE ISSUANCE OF A
HOLD DEPARTURE ORDER AGAINST ACCUSED

1. In 2010, a warrant of arrest was issued by this Honorable

Court against the Accused.

2. Despite the issuance of the said warrant, the Accused failed

to surrender and evaded arrest for several months.

3. This is a clear indication that Accused is a flight risk and the

high probability that the Accused will depart from the Philippines to
evade arrest and prosecution of crime against him.

4. Most recently, the Accused was also granted visitation

rights. The hold departure order is an assurance that Accused will not
leave the country and take BBB with him pending the criminal case
against him.

5. Thus, to ensure the safety of the minor child and to minimize

the probability of flight, it is imperative that the Accused be placed in
the hold departure order list of the Bureau of Immigration.

6. Under Section 32 of RA 9262, “The court shall expedite the

process of issuance of a hold departure order in cases prosecuted under
this Act.”

7. In view thereof, private complainant moves for the

immediate issuance of a hold departure order against the accused to
ensure proper dispensation of justice.

8. For the guidance of the Honorable Court, we furnish the

complete data of the accused, AAA, to wit:
 Complete Name of the Accused: AAA
Sex: Male
Civil Status: Single
Date of Birth: XXX
Place of Birth: XXX
Address: XXX

ALLEGATIONS IN SUPPORT OF THE ISSUANCE OF A

TEMPORARY PROTECTION ORDER

xxx

PRAYER

WHEREFORE, premises considered, Private Complainant most

respectfully prays that a Hold Departure Order and Temporary
Protection Order be immediately issued against the Accused.

Other measures of relief, just and equitable under the premises,

are likewise prayed for.

San Juan City for ______________, _________ 2019.

counsel

With conformity:
OFFICE OF THE CITY PROSECUTOR

Laguna

Copy furnished:

AAA

Laguna

NOTICE OF HEARING

THE CLERK OF COURT

Regional Trial Court

Laguna

Please set for hearing the foregoing motion on October 30, 2010 at
8:30 a.m. or immediately upon receipt thereof for the consideration and
resolution of the Honorable Court.

ATTY. AAA

EXPLANATION
(Pursuant to Section 11, Rule 13 of the Rules of Court)

Copy of the foregoing pleading was sent to the above-named

addressees by registered mail. Personal service is impracticable due to
distance, time constraints and lack of personnel to effect personal
service.

ATTY. AAA