Motion To Avail of Plea Bargaining

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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT


Fourth Judicial Region
BRANCH 32
San Pablo City

PEOPLE OF THE PHILIPPINES,


Plaintiff, Crim. Case no. 25430-SP

For: Violation of Section 5, Art. II,


of Republic Act no.9165

RANNIELSABINIANO y AMBAL,
Accused,
x-----------------------x

MOTION TO AVAIL OF PLEA BARGAINING

Comes now, accused Ranniel Sabiniano y Ambal, assisted by the undersigned


counsel, unto this Honorable Court, most respectfully sets forth that:

1. Accused was charged for Violation of Section 11, Article II of Republic Act no.
9165 before this Honorable Court;

2. The said criminal case is still pending before this Honorable Court;

3. Accused offers to plea bargain as sanctioned by the En banc Decision in G.R.


No. 226679 – Salvador Estipona, Jr. vs. Hon. Frank Lobrigo, wherein he would
plead to the lesser offense under Supreme Court Guidelines A.M. No. 18-
03-16-SC available in R.A. 9165, subject to the conditions that may be imposed
by the Court in accordance with the said guidelines;

4. That in the event that this motion be granted, the accused likewise prays
that he be allowed to avail of the Probation Law;

WHEREFORE, premises considered, it is most respectfully prayed upon this


Honorable Court that this motion be considered and granted.

Praying for such other relief and remedies equitable under the premises.

San Pablo City, November 12, 2018.

ATTY. ARVIN C. LLEGO


Roll of Attorney No. 71366
(Newly admitted to the Bar)

With my conformity:

RannielA. Sabiniano
Accused
The Branch Clerk of Court
Regional Trial Court
Branch 32, San Pablo City

Greetings:

Kindly submit the foregoing motion for consideration and approval by this
Honorable Court immediately upon receipt hereof.

ATTY. ARVIN C. LLEGO

Copy furnished:

______________________
Office of the City Prosecutor
San Pablo City

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