REPUBLIC OF THE PHILIPPINES

FAMILY COURT
NATIONAL CAPITAL JUDICIAL REGION
BRANCH ABC, 1234 CITY

PEOPLE OF THE PHILIPPINES,

Plaintiff,
Crim. Case No. 12345678
- versus - For: Viol. of Sec. 10(a), RA 7610
(Other Acts of Child Abuse)
MAY SALTIK y BAGTIT,
Accused.
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MOTION FOR MENTAL CONFINEMENT

ACCUSED MAY SALTIK y BAGTIT, through the undersigned

counsel, to this Honorable Court, most respectfully states that:

1. Accused is charged with Other Acts of Child Abuse

penalized under Section 10(a) of R.A. 7610. To date, the accused has
yet to be arraigned due to her mental condition;

2. Accused was first brought to the National Center for

Mental Health (NCMH) on January 11, 2017 for mental evaluation to
determine whether she is fit for trial. Per NCMH’s Initial Report dated
January 21, 2018, accused was found to be suffering from psychiatric
disorder, making accused incompetent to stand trial;

3. On at least four (4) dates thereafter, i.e. March 22, 2017,

May 3, 2017, June 7, 2017, and July 12, 2017, the accused was brought
to NCMH for follow-up psychological examination;

4. In its Report dated 30 April 2018, NCMH reported that

based on the history, mental status examination, observations, and
psychological tests, accused is diagnosed to be suffering from a
psychosis classified as Schizophrenia. NCMH also reported that per
their records, the accused has been undergoing outpatient
evaluation/follow at NCMH’s Forensic Psychiatry Section since
February 2009;

5. In its letter to the Honorable Court dated 16 July 2018, Dr.

XYZ, Chief of NCMH’s Forensic Psychiatry Section, reported that based
on their latest examination on the accused on July 00, 2018, the latter
remained incompetent to stand trial;
 6. As could be observed, it appears that the mental
condition of the accused has not been improving despite several
follow-ups at the NCMH. Per consultation with the family of the
accused, the latter has signified their intention to have the accused
admitted and confined at the NCMH so she could be given proper
treatment and intervention. With utmost respect, the family believes
that accused’s detention at a jail facility only exacerbates her mental
condition and that the personnel of the 123 City BJMP cannot provide
the treatment, care, and attention the accused’s mental condition
requires;

7. Pursuant to Section 11, Rule 116 of the Revised Rules of

Criminal Procedure, and in the interest of justice and for
humanitarian reasons, it is humbly prayed that accused be
transferred and placed in confinement at the National Center for
Mental Health so she may be given the proper treatment and
intervention given her worsening mental condition.

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed of this Honorable Court that an Order be issued allowing the
accused to be transferred and placed in confinement at the National
Center for Mental Health for proper mental treatment and
intervention.

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

September 2, 2018, 123 City.

ATTY. ABC XYZ

Counsel for the Accused
Roll No. 00000
IBP Life Member Roll No. 00001
MCLE Compliance No. 00002

The Branch Clerk of Court

Family Court Branch ABC
123 City

Greetings!

Please take notice that the undersigned counsel will submit the
foregoing Motion for Confinement for consideration and approval of the
Honorable Court on September 00, 2018 at 9:30 in the evening where
the Honorable Court sits.

ATTY. ABC XYZ

Copy furnished:

Hon. Trial Prosecutor

Office of the City Prosecutor
City of 123