Republic of the Philippines

REGIONAL TRIAL COURT

Third Judicial Region
City of Malolos, Bulacan
BRANCH ____

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- Crim Case No. _____________

_________________________________,
Accused.
X-------------------------------------------------X

URGENT MOTION TO ALLOW ACCUSED TO UNDERGO SCREENING &

DRUG DEPENDENCY EVALUATION/ EXAMINATION AT THE BULACAN
TREATMENT AND REHABILITATION FOUNDATION INC.
& BULACAN HOME CARE.

Accused, ________________________________, assisted by

_______________________________________________, through the undersigned
counsel, unto this Honorable Court, most respectfully aver;

1. On 30th January 2019 the Honorable Court granted the Motion to Plead
Guilty to a Lesser Offense filed by the accused and directed the person
in custody of the accused to bring the latter to Dra. Jocelyn Gomez and
Dra. Cindy Canlas at the Bulacan Provincial Health Office for purposes
of Screening and Drug Dependency Evaluation/ Examination within
seventy (72) hours from receipt of the resolution;

2. Up to this date, accused was never brought to Dra. Jocelyn Gomez and
Dra. Cindy Canlas at the Bulacan Provincial Health Office for purposes
of Screening and Drug Dependency Evaluation/ Examination. That
upon inquiry with the person in custody (BJMP BALAGTAS) of the
accused, the former stated that the “line-up” for the Screening and Drug
Dependency Evaluation/ Examination at the Bulacan Provincial Health
Office is filled and that the accused have to wait for months before he can
be accommodated, hence this motion;

3. Accused humbly seeks the permission of the Honorable Court that he be

allowed to undergo SCREENING & DRUG DEPENDENCY
EVALUATION/ EXAMINATION at THE BULACAN TREATMENT
AND REHABILITATION FOUNDATION INC. & BULACAN HOME
CARE1 on 23 March 2019 at 8:00 in the morning at Ting’s Ville, San
Nicolas Bulakan (3017) Bulacan, Philippines.

1
DOH Accreditation No. DATRC 03-07-14-50-DR-2
 WHEREFORE, premises considered, it is respectfully prayed of this
Honorable Court that accused ______________________________________ be
allowed to undergo SCREENING & DRUG DEPENDENCY EVALUATION/
EXAMINATION at THE BULACAN TREATMENT AND REHABILITATION
FOUNDATION INC. & BULACAN HOME CARE, on 23 March 2019 at 8:00 in the
morning.

Other just and equitable reliefs are likewise prayed for.

Respectfuly filed. City of Malolos, Bulacan. 19 March 2019.