MOTION For Reconsideration - Lapanday

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REPUBLIC OF THE PHILIPPINES

Department of Justice
OFFICE OF THE PROVINCIAL PROSECUTOR
Digos City, Davao del Sur

JOEL CAMPOS DALGUNTAS,


Complainant,

NPS- Docket No. XI-04-INV-20K-00274

-versus- FOR : QUALIFIED THEFT

JAKE BEMITO FELICIANO AND


MICHAEL JOHN OLANDAC JOSOL
Respondents.
x--------------------------------------x

MOTION FOR
RECONSIDERATION
COMES NOW, Complainant, assisted by the undersigned
counsel and unto this Honorable Office, respectfully states:

That a RESOLUTION dated December 29, 2020 and


promulgated on April 13, 2021 was received by complainant last April
15, 2021;
That said Resolution recommends for the DISMISSAL WITHOUT
PREJUDICE of the above-captioned case for failure to allege the
estimated amount of the things stolen, the dispositive portion of
which reads as follows:

“WHEREFORE, premises considered, the undersigned hereby


recommends the dismissal of this case without prejudice to its re-
filing”.

hence this MOTION FOR RECONSIDERATION;

Motion for Reconsideration(Dalguntas vs. Felicino, et al.) Page 1


To satisfy the requirement of the law, complainant hereby
submits his SUPPLEMENTAL AFFIDAVIT (herein attached as
Annex “A”) alleging the total amount of the things stolen.

WHEREFORE, premises considered, it is prayed that this


Honorable Office RECONSIDERS its RESOLUTION dated
December 29, 2020 and files appropriate charges against herein
respondents.

Other relief just and equitable are likewise prayed for.

Digos City, Davao del Sur, Philippines. April 26, 2021

ATTY. ANNA MARGARITA A. RAZONABLE-MAMUAD


Counsel for the Complainant
AMARA LAW
2F DASURBACO Bldg.
Magsaysay-Jacinto Sts., Digos City, 8002 Davao del Sur
Roll of Attorneys 46708
MCLE COMPLIANCE NO. VI-0002745/April 14, 2022
PTR NO. 8584607/ January 5, 2021, Davao del Sur
IBP NO. (On Process) paid on January 6, 2021
Contact No. 0917-117-8870
email add: amara_law2001@yahoo.com

Copy furnished:

JAKE BENITO FELICIANO and


MICHAEL JOHN OLANDAC JOSOL - Sitio Budoy, Brgy. Guihing, Hagonoy, Davao del Sur

Motion for Reconsideration(Dalguntas vs. Felicino, et al.) Page 2

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