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    Regional Trial Court Branch Xxii: Criminal Case Nos. 22-3882

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    YNNA DERAY
    The accused, Jojo Dumaliang y Acosta, is submitting a plea bargaining offer to the court for three criminal cases charging him with various offenses. He proposes to plead guilty to lesser offenses, including pleading guilty to violating Section 4 of RA 8294 instead of Section 1 of RA 9516, and Section 31 of RA 10591 instead of Section 28g of RA 10591. He also proposes withdrawing the charge under Section 11 of RA 9165. The plea bargaining offer is submitted with the consent of the offended party and prosecutor.

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    Regional Trial Court Branch Xxii: Criminal Case Nos. 22-3882

    Uploaded by

    YNNA DERAY
    350 views4 pages
    The accused, Jojo Dumaliang y Acosta, is submitting a plea bargaining offer to the court for three criminal cases charging him with various offenses. He proposes to plead guilty to lesser offenses, including pleading guilty to violating Section 4 of RA 8294 instead of Section 1 of RA 9516, and Section 31 of RA 10591 instead of Section 28g of RA 10591. He also proposes withdrawing the charge under Section 11 of RA 9165. The plea bargaining offer is submitted with the consent of the offended party and prosecutor.

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    LAW, BARGAIN

    Original Title

    pleabargainDUMALIANG

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    The accused, Jojo Dumaliang y Acosta, is submitting a plea bargaining offer to the court for three criminal cases charging him with various offenses. He proposes to plead guilty to lesser offenses, including pleading guilty to violating Section 4 of RA 8294 instead of Section 1 of RA 9516, and Section 31 of RA 10591 instead of Section 28g of RA 10591. He also proposes withdrawing the charge under Section 11 of RA 9165. The plea bargaining offer is submitted with the consent of the offended party and prosecutor.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    350 views4 pages

    Regional Trial Court Branch Xxii: Criminal Case Nos. 22-3882

    Uploaded by

    YNNA DERAY
    The accused, Jojo Dumaliang y Acosta, is submitting a plea bargaining offer to the court for three criminal cases charging him with various offenses. He proposes to plead guilty to lesser offenses, including pleading guilty to violating Section 4 of RA 8294 instead of Section 1 of RA 9516, and Section 31 of RA 10591 instead of Section 28g of RA 10591. He also proposes withdrawing the charge under Section 11 of RA 9165. The plea bargaining offer is submitted with the consent of the offended party and prosecutor.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    of 4

    Republic of the Philippines

    REGIONAL TRIAL COURT


    Second Judicial Region
    BRANCH XXII
    Cabagan, Isabela

    PEOLE OF THE PHILIPPINES, Criminal Case Nos. 22-3882


    Plaintiff,

    -versus- FOR: VIOLATION OF RA 10591

    JOJO DUMALIANG y ACOSTA,


    Accused.
    x---------------------------------------------x

    PEOLE OF THE PHILIPPINES, Criminal Case Nos. 22-3883


    Plaintiff,

    -versus- FOR: VIOLATION OF RA 9516

    JOJO DUMALIANG y ACOSTA,


    Accused.
    x---------------------------------------------x
    PEOLE OF THE PHILIPPINES, Criminal Case Nos. 22-3884
    Plaintiff,

    -versus- FOR: VIOLATION OF RA 9165

    JOJO DUMALIANG y ACOSTA,


    Accused.
    x---------------------------------------------x

    PLEA BARGAINING OFFER

    The Accused, JOJO DUMALIANG y ACOSTA, through


    counsel on record, most respectfully submits the allowing Plea
    Bargaining Proposal for the Honorable Court's consideration and
    approval, and state:

    1. That the Accused was charged on August 3, 2018 with the


    following:

    a. Violation of Section 28g, Republic Act No. 10591


    b. Violation of Section 1, Republic Act No. 9516, and
    c. Violation of Section 11, Republic Act No. 9165
    2. That Accused comes before the Honorable Court to express his
    intention to avail the benefits of plea bargaining as provided in
    the 1987 Constitution and the Rules on Criminal Procedure
    particularly Section 2, Rule 116 of the Revised Rules of
    Criminal Procedure, to wit;

    “Sec. 2. Plea of guilty to a lesser offense. – At


    arraignment, the accused, with the consent of the
    offended party and prosecutor, may be allowed by the
    trial court to plead guilty to a lesser offense which is
    necessarily included in the offense charged. After
    arraignment but before trial, the accused may still be
    allowed to plead guilty to said lesser offense after
    withdrawing his plea of not guilty. No amendment of the
    complaint or information is necessary.”

    3. Plea bargaining in criminal cases, is a process whereby the


    accused and the prosecution work out a mutually satisfactory
    disposition of the case subject to court approval. It usually
    involves the defendant’s pleading guilty to a lesser offense or to
    only one or some of the counts of a multi-count indictment in
    return for a lighter sentence than that for the graver charge. 1 

    4. The accused humbly proposes to enter his plea of guilt to the


    following:

    a. From Violation of Section 28g Republic Act No. 10591 to


    Section 31 of Republic Act No. 10591.
    b. From Violation of Section 1 of Republic Act No. 9516 for
    Illegal Possession of Explosives to Violation of Section 4
    of RA No. 8294;
    c. Withdrawal/dismissal of the Information charging the
    accused with Section 11, RA No. 9165.

    PRAYER

    WHEREFORE, it is most respectfully prayed unto the


    Honorable Court to allow the accused to enter a plea of guilt to the

    1
    Daan vs. Sandiganbayan, G.R. Nos. 163972-77, March 28, 2008
    lesser offenses of Violation of Section 4 RA No. 8294 2 and Violation
    of Section 31, RA No. 10591.3

    Accused further pray for other reliefs just and equitable under
    the premises.

    March 3, 2021. Cabagan Isabela

    Assisted by:

    Department of Justice
    PUBLIC ATTORNEY’S OFFICE
    Cabagan District Office
    Cabagan, Isabela

    By:

    ATTY. NICANOR G. GARCIA


    District Public Attorney

    ATTY. MARICION B. CAPILI - GUINGAB


    Public Attorney II

    With our conformity:

    PROS. REMELYN DALAFU A. TAGAO


    Prosecutor II
    OPP – Cabagan, Isabela

    PROS. MA. CHRISTINA P. DELA ROSA


    Provincial Prosecutor
    Office of the Provincial Prosecutor – Isabela
    2
    Section 4. Sec. 6 of Presidential Decree No. 1866, as amended, is hereby further
    amended to read as follows:

    "Sec. 6. Repacking or altering the composition of lawfully manufactured explosives. –


    The penalty of prision correccional shall be imposed upon any person who shall
    unlawfully repack, alter or modify the composition of any lawfully manufactured
    explosives."

    3
    Section 31. Absence of Permit to Carry Outside of Residence. – The penalty of prision
    correccional and a fine of Ten thousand pesos (P10,000.00) shall be imposed upon any
    person who is licensed to own a firearm but who shall carry the registered firearm outside
    his/her residence without any legal authority therefor.
    Copy furnished:

    PO1 JERIC CURIBANG


    PNP DELFIN ALBANO, ISABELA

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