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Motion To Inhibit

This document is a motion to inhibit filed in a criminal case in the Philippines. It requests that the investigating prosecutor inhibit himself from resolving the criminal complaint due to an unreasonable delay in rendering a resolution, causing prejudice to the complainant. It alleges that the complaint was filed in May 2011 but no resolution has been issued despite several follow-ups. The motion prays that the investigating prosecutor inhibit himself to avoid the appearance of bias or impropriety. Copies of the motion were furnished to the prosecutor, defendant's counsel, and another counsel via private courier due to the distance making personal service impracticable.

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Joemar Caluna
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93 views2 pages

Motion To Inhibit

This document is a motion to inhibit filed in a criminal case in the Philippines. It requests that the investigating prosecutor inhibit himself from resolving the criminal complaint due to an unreasonable delay in rendering a resolution, causing prejudice to the complainant. It alleges that the complaint was filed in May 2011 but no resolution has been issued despite several follow-ups. The motion prays that the investigating prosecutor inhibit himself to avoid the appearance of bias or impropriety. Copies of the motion were furnished to the prosecutor, defendant's counsel, and another counsel via private courier due to the distance making personal service impracticable.

Uploaded by

Joemar Caluna
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

REPUBLIC OF THE PHILIPPINES,

Complainant,

-versus-

______________________,

Accused.

x - - - - - - - - - - - - - - - - - - - - - - - - -x

CRIMINAL CASE NO. _______________

FOR: _________________

MOTION TO INHIBIT

Complainant, by counsel, to the Honorable Court, alleges that:

The instant complaint was filed sometime in 06 May 2011. However, up to this time, no
resolution has yet been issued by the honorable office;

This has been the case despite several follow-ups made by the complainant and it is very
apparent that there is an unreasonable delay in rendering the resolution to the extreme
prejudice of the complainants;

In view of the foregoing, to avoid the appearance of bias and impropriety, it is most
respectfully prayed of the Honorable Office that the honorable investigating prosecutor
inhibit himself from resolving this criminal complaint.

Other reliefs just and equitable are likewise prayed for.

City of Manila, for Imus City, 25 May 2012.


PARIL LAW OFFICE

Counsel for Private Complainant

1080 Negros Street, Balic- Balic

Sampaloc, Manila
by:

JEFFREY PARIL

IBP#__________, __________Chapter, __________

PTR#__________, __________, __________, __________

Attorney’s Roll No. __________

MCLE Compliance No. II- __________

MCLE Compliance No. III- __________

MCLE Compliance No. IV- __________

Copy Furnished:

PROSECUTOR JACK MIOF

Office of the City Prosecutor

Imus City, Cavite

ATTY. ALEXANDER LIQUIGAN

Unit 3C, De Quiroz Bldg.,

Aguinaldo Highway, Perpetual Village,

Palico III, Imus City, Cavite

ATTY. RAPHAEL CORONADO

2nd Floor, RCVJ Building,

Don P. Campa Avenue, Barrio Uno,

2662 Dasmarinas City, Cavite

Explanation
Copy of the Motion was furnished to the respondent by private courier due to the distance of
the undersigned from the said parties, making personal service thereof not practicable.

JEFFREY PARIL

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