BAHASUAN

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Republic of the Philippines

REGIONAL TRIAL COURT


11th Judicial Region
Branch 47
Alabel, Sarangani Province

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. 01106-19


Plaintiff, (NPS DOCKET NO. XII-07-INV-
19A-00020)

-versus- -for-

MANGACOY BAHASUAN y VIOLATION OF PARAGRAPH (G)


COLANO A.K.A. ABDULBASER OF SECTION 28, ARTICLE V,
COLANO BAHASUAN ALIAS R.A. 10591
ACOY,
Accused.
x-------------------------------------x

OFFER TO PLEAD GUILTY TO A LESSER OFFENSE

ACCUSED, through counsel from the Public Attorney’s Office,


and unto this Honorable Court, most respectfully states that:

1. Accused stands charged for the alleged


violation of Section 28 (G), Article V of R.A. 10591 by
willfully, unlawfully and deliberately possessing three (3)
pieces of live ammunition of caliber .30 M1 Garand on or
about 2:30 in the morning of 24 January 2019 at Purok
Bahasuan, Barangay Sapu Masla, Municipality of
Malapatan, Sarangani Province;

2. However, pursuant to provisions on plea


bargaining, accused hereby offers to plead guilty to the
lesser offense of violation of Section 31 of R.A 10591
which is punishable by penalty of prision correccional and
a fine of Ten thousand pesos (P10,000.00);

3. The plea bargaining will be convenient to the


State as the cases will be promptly dissolved and will
result to declogging of cases in court;

PP vs. Bahasuan, Criminal Case No.01106-19, Violation of Section 28 (G),


Article V, R.A. 10591
Page 1 of 3
4. The plea bargaining offered by the accused
will not serve to trivialize the seriousness of the charge
against him and send the wrong signal to potential
offenders that the penalties they are likely to face would
be lighter than what their criminal acts would have
merited;

5. Accused respectfully and humbly prays that


should his offer be given due course, accused undertakes
to start a new life;

PRAYER

WHEREFORE, it is most respectfully prayed that the offer to


plead guilty for a lesser offense by the accused, with the conformity
of the prosecution, BE GIVEN DUE COURSE, and that the penalty to
be imposed upon him is within the range of Prision Correccional.

Alabel, Sarangani Province, 23 April 2019.

RESPECTFULLY SUBMITTED:

NESTONI M. SENARILLOS
Public Attorney I
Roll of Attorney No. 67653
PTR exempt under Section 139 (d) of R.A. 7160
MCLE Compliance Exempt per OCA Cir. No. 76-2008

With our conformity:

MANGACOY BAHASUAN y P01 RAKIM P. NOMER


COLANO Complainant/Arresting Officer
Accused

Recommended by: Approved by:

PROS. ANDRES B. MISSION, JR. PROS. ELMER D. LASTIMOSA


Counsel for the Plaintiff Provincial Prosecutor

PP vs. Bahasuan, Criminal Case No.01106-19, Violation of Section 28 (G),


Article V, R.A. 10591
Page 2 of 3
NOTICE

The Clerk of Court


Branch 47
Alabel, Sarangani Province

G r e e t i n g s:

Please submit the foregoing Application Offer To Plead Guilty


To a Lesser Offense on 09 May 2019 at 8:30 o’clock in the morning
or at the available date and time of the Honorable Court for its the
consideration and approval.

NESTONI M. SENARILLOS

Provincial Prosecutor’s Office


Alabel, Sarangani Province

G r e e t i n g s:

Please take notice that the foregoing Offer To Plead Guilty To a


Lesser Offense will be submitted on 09 May 2019 at 8:30 o’clock in
the morning or at the available date and time of the Honorable Court
for its consideration approval.

NESTONI M. SENARILLOS

Copy furnished:

PROS. ANDRES B. MISSION JR., Received by:______________


Counsel for the Plaintiff Date received:_____________
Office of the Provincial Prosecutor
Alabel, Sarangani Province

PP vs. Bahasuan, Criminal Case No.01106-19, Violation of Section 28 (G),


Article V, R.A. 10591
Page 3 of 3

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