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REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGIONAL


MUNICIPAL TRIAL COURT IN CITIES
BRANCH 1
Pallocan West, Batangas City

PEOPLE OF THE PHILIPPINES,


Plaintiff,
Criminal Case No. 59988
-versus- For: THEFT

JUSTIN CANIEDA VELASCO,


CHERRISH RAMIREZ YBAÑEZ,
DANILYN DIAMANTE
MADRIGAL and MHARA
FESARILLO CESAR,
Accused.
X------------------------X

MOTION FOR PERMANENT DISMISSAL

ACCUSED DANILYN DIAMANTE MADRIGAL and MHARA


FESARILLO CESAR, unto this Honorable Court most respectfully state that:

1. The present case was provisionally dismissed on March 14, 2018.

2. One year has passed and the prosecutor nor private complainant has not
filed for the revival of the case; thus, the dismissal having attained
finality.

3. Undersigned accused now move and beg the indulgence of this


Honorable Court that it issue an Order making the dismissal permanent.

4. This Motion is not intended to delay the case but is prompted sole by
the afore-cited reason.

PREMISES CONSIDERED, it is most respectfully prayed of this


Honorable Court that it issue an Order permanently dismissing the present
case.

Other reliefs, just and equitable under the premises are likewise prayed
for.

Batangas City, 18 March 2019.

DANILYN DIAMANTE MADRIGAL MHARA FESARILLO CESAR


Notice of Hearing

Pros. Redeemer B. Faraon


Office of the City Prosecutor
Hall of Justice
Pallocan West, Batangas City

Atty. Maria Aisa O. Dimacuha


Public Attorney’s Office
Hall of Justice
Pallocan West, Batangas City

Hon. Clerk of Court


Branch 1
MTCC – Batangas City

Greetings!

Kindly set this motion for consideration of this Honorable Court on


March 22, 2019 at 8:30 o’clock in the morning or at any date and time
convenient to the calendar of the Honorable Court.

DANILYN DIAMANTE MADRIGAL MHARA FESARILLO CESAR