REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 7 – BATANGAS CITY

THE PEOPLE OF THE PHILIPPINES

Plaintiff,

CRIM. CASE NO. 201619

-versus- -for-

Violation of Art. II, Sec. 5 of RA

9165

PETRONILO ALVAR,
Accused.
X -------------------------------------------------- X

MOTION TO ALLOW ACCUSED TO VISIT

BROTHER’S WAKE

Accused, thru the undersigned counsel de oficio and

unto this Honorable Court, most respectfully states:

That accused is presently detained at the Batangas

Provincial Jail, Cuta, Batangas City due to the above-
entitled case;

That the brother of the accused, GILBERT ALVAR,

passed away on April 28, 2016 as evidenced by his
Certificate of Death which is hereto attached as Annex
“A”;

That accused would like to pay his last respects to his

brother whose remains lie in state in their residence in Brgy.
3, Poblacion, Bauan, Batangas, and attend the wake on
May 3, 2016 at 2:00 o’clock in the afternoon;

That for humanitarian reasons, accused through

counsel, most respectfully requests that he be allowed to
visit his brother’s wake at Brgy. 3, Poblacion, Bauan,
Batangas;

WHEREFORE, premises considered, it is

respectfully prayed of this Honorable Court that this MOTION
be granted.

Other reliefs, just and equitable under the premises are

likewise prayed for.

Batangas City, May 2, 2016.

 PUBLIC ATTORNEY’S OFFICE
DEPARTMENT OF JUSTICE
BATANGAS DISTRICT OFFICE
HALL OF JUSTICE, BATANGAS CITY
Counsel for the Accused

By:

ARSENIO M. HERNANDEZ JR.

Public Attorney 2
Roll No. 49087
MCLE Compliance No. v-00153358

Conformity:

Provincial Prosecutor
Batangas City

The Branch Clerk of Court

Regional Trial Court
Branch 7 – Batangas City

GREETINGS:

Kindly submit the foregoing Motion to the Honorable

Court for His Honor’s consideration and approval
immediately upon receipt hereof.

ARSENIO M. HERNANDEZ JR.

Copy furnished:

Provincial Prosecutor Office

Batangas City