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Republic of the Philippines

1st MUNICIPAL CIRCUIT TRIAL COURT
MUNICIPALITY OF _______
PROVINCE OF ANTIQUE

ORIGINAL COPY:

PEOPLE OF THE PHILIPPINES,

-versus- Criminal Case No.: 111111

FOR: Violation of Section 75 (e)

of PD 856 (Code on Sanitation
of the Philippines)

Son Guko
Accused.
X---------------------------X

MOTION FOR SUBSTITUTION OF WITNESS

COMES NOW, ACCUSED, through the undersigned counsel, and unto this
Honorable Court, most respectfully states, THAT:

1. Under the PRELIMINARY CONFERENCE ORDER, the next witness for

the ACCUSED is pedro penduko, San Jose, Antique;

2. However, the issue involved in the present case involves the interpretation
of an esoteric law which not many is adept in;

3. Ergo, it serves the interest of justice, the ACCUSED be allowed to

substitute witness for her defense;

4. Germane to the foregoing, the proper government entity to coordinate

with is the Integrated Provincial Health Office (IPHO), it being the agency
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tasked with monitoring compliance with PD 856, through its sanitary

inspectors;

5. Thus, there is compelling necessity for this Honorable Court to allow the
ACCUSED to present the substitute witness in the person of Dr. Picolo
Provincial Health Officer, Provincial Health Office;

PRAYER

WHEREFORE, it is most respectfully prayed of this Honorable Court that the

ACCUSED be permitted to substitute her witness for her defense.

It is also most respectfully prayed of this Honorable Court that Dr. picolo, ,
Provincial Health Office, be the ACCUSED’ substitute witness and be allowed to
submit JUDICIAL AFFIDAVIT of said witness.

Other reliefs and remedies which to this Honorable Court may be just and
equitable are also prayed for.

San Jose de Buenavista, for Hamtic, Antique, November 3, 2019.

majimbo
Counsel for the Accused
San Jose de Buenavista, Antique
by: