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Republic of the Philippines

REGIONAL TRIAL COURT


Second Judicial Region
BRANCH XXXXXXXXX
ZZZZZZZ

PEOPLE OF THE
PHILIPPINES,
Plaintiff, CRIM. CASE NO. 1234567

For: Violation of Sec. 11,


-versus- Article II of R.A. No. 9165

XXXXXXXXXXXXXXXXX,
Accused.
x--------------------------------------x

APPLICATION FOR PROBATION

ACCUSED XXXXXXXXXXXXXXXX, with the assistance of


his counsel and unto this Honorable Court, most respectfully applies
for probation under the provisions of Presidential Decree No.
968, as amended, and for this purpose, most respectfully states that:

1. On 26 April 2019, the accused was allowed to plead guilty to


the lesser of offense of violation of Section 12, Article II of R.A. No.
9165 or for Possession of Equipment, Instrument, Apparatus and
Other Paraphernalia for Dangerous Drugs pursuant to A.M. No. 18-
03-16-SC.

2. Thereafter, accused was re-arraigned and he pleaded guilty to


Section 12, Article II of R.A. No. 9165. The Honorable Court, on even
date or on 26 April 2019, thus, promulgated its Decisions and
imposed upon herein accused the straight penalty of one (1) year of
imprisonment.

3. Under the applicable rules and settled jurisprudence, the


accused have a period of fifteen (15) days from the said date of
promulgation or until 11 May 2019 within which to file his
Application for Probation.

4. Considering that this Application for Probation for the accused


shall be filed today, _ April 2019, it is therefore, filed on time.

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5. The crime for which the accused was convicted is not among
those offenses provided by law that may render a convicted person
disqualified from applying for probation.

6. The accused has not been previously convicted by final


judgment of any offense punishable by imprisonment of not less than
one (1) month and one (1) day and/or fine of not less than Two
Hundred Pesos (Php200.00).

7. The accused has never been placed on probation under the


provisions of Presidential Decree No. 968, otherwise known as
the Probation Law of 1976, as amended, and it is only the first time
that the accused sought the benefits under the Probation Law.

8. Considering that herein accused has all the qualifications and


none of the disqualifications to avail of the benefits of the Probation
Law and considering the fact that the same is more favorable to
herein accused and in order for him to be reintegrated again in the
society as enshrined in declaration of policy under R.A. No. 9165,
herein accused most respectfully requests for the favorable
recommendation of the Parole and Probation Officer of Cauayan City,
Isabela and the benevolent approval of the Honorable Court of the
instant Application for Probation.

9. Herein accused most respectfully request of this Honorable


Court that he be allowed of his provisional liberty under the same bail
bond which he posted pending the resolution of his application for
probation.

PRAYER
WHEREFORE, premises considered, it is most respectfully
prayed of this Honorable Court that the Application for Probation of
ACCUSED XXXXXXXXXX be referred to the Parole and
Probation Officer of SADASDAD for the requisite Post-Sentence
Investigation and thereafter, an Order be issued APPROVING his
Application for Probation.

Other reliefs, just and equitable under the circumstances, are


likewise prayed for.

Santiago City, Philippines. _ April 2019.

DELA CRUZ & ASSOCIATES LAW OFFICES


Counsel for the Accused
No. 8 Maharlika Highway, Dubinan East
Santiago City
Tel No. 31431431
E-mail: @gmail.com
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By:

YYYYYYYYYYYYYYYYY
Roll of Attorneys No. 1214411
IBP Lifetime No. 121412, 2 May 2001
PTR No. SC 1212141, Santiago City, 7 January 2019
Isabela Chapter
MCLE Compliance Certificate No. VI-0213123414 valid until 14 April
2022
E-mail: @gmail.com

VVVVVVVVVVVVVVVV
Roll of Attorneys No. 1212344
IBP Lifetime No. 12412314, 13 March 2018
PTR No. SC 12133415, Santiago City, 10 January 2019
Isabela Chapter
MCLE Compliance Certificate No. VI – 2321421 valid until 14 April 2022
Mobile Phone No. 2141241324
E-mail: @gmail.com

WITH MY CONFORMITY:

XXXXXXXXXX
Accused

NOTICE OF HEARING:

HON. AAAAAAAAAAAAA
Government Prosecutor
Office of the City Prosecutor
ZZZZZZZZZZZZZ
*Through registered mail

ATTY. AAAAAAAAAAAAAAAA
Branch Clerk of Court
Regional Trial Court, Branch 1242
ZZZZZZZZZZ
*Through registered mail

G r e e t i n g s: Due to the extreme urgency, please take notice that


the undersigned counsel shall submit the foregoing motion for the
consideration and resolution of the Honorable Court immediately
upon receipt hereof without further oral arguments and even without
the presence of the undersigned. Thank you.

UUUUUUUUUUUYYYYYYYYYYY
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Copy furnished:

HON. AAAAAAAAAAAAA
Government Prosecutor
Office of the City Prosecutor
ZZZZZZZZZZZZZ
*Through registered mail

ATTY. AAAAAAAAAAAAAAAA
Branch Clerk of Court
Regional Trial Court, Branch 1242
ZZZZZZZZZZ

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