Republic of the Philippines

REGIONAL TRIAL COURT

7th Judicial Region
Branch 7
Cebu City

PEOPLE OF THE PHILIPPINES

Plaintiffs, Criminal Case No. CBU-101993
& CBU-101994
-versus-
For: Violation of R.A. 8294
IAN DE GRACIA LABAJO,
Accused.
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-/

MOTION FOR LEAVE OF COURT TO FILE

DEMURRER TO EVIDENCE

ACCUSED, through the undersigned counsel, unto this

Honorable Court, most humbly and respectfully states that:

1. That the prosecution in the above entitled case has already

rested its case;

2. That the defense believes that the evidence of the prosecution

against the accused is insufficient to establish the guilt of the
accused beyond reasonable doubt, thus, the defense prays for
leave to file demurrer to evidence in accordance with Section
23, Rule 119 of the 2000 Revised Rules on Criminal Procedure.

PRAYER

WHEREFORE, premises on the foregoing consideration and in

the highest interest of justice, it is most respectfully prayed of this
Honorable Court that the aforesaid motion be granted.

Other reliefs which are just and equitable are likewise prayed.

Respectfully submitted. Cebu City, Philippines, September 25,

2020.

P.B. LABRADO AND PARTNERS LAW OFFICES

1
 Counsel for the Accused
Room 202, 2nd Floor, Aniceta Bldg.,
Osmeňa Blvd., Cebu City
Tel. No. (032) 405 3099

By:

MARC CHRISTIAN H. TANGPUZ

Roll of Attorneys No. 72435
PTR No. 502224; Cebu Province, January 10, 2020
IBP No. AR43284160; Cebu Province, January 10, 2020
MCLE Compliance No. VII-0001477 valid until April 14, 2025
Room 202, Aniceta Bldg. Osmena Blvd., Cebu City
Cell No. 0939 397 6604
marcchristiantangpuz@gmail.com

REQUEST

THE BRANCH CLERK OF COURT

RTC Branch 7 – Cebu City
Cebu City Hall of Justice
Qimonda Bldg., North Reclamation Area
Cebu, Philippines

Greetings! Please submit and set the foregoing Motion for

consideration of the Honorable Court on October 2, 2020 at 8:30
o’clock in the morning with the presence of counsel and further
argument.

Honorable Prosecutor shall kindly take notice. Thank you very

much.

Respectfully submitted. Cebu City, Philippines, September 25,

2020.

MARC CHRISTIAN H. TANGPUZ

Copy furnished:

PROS. CHRISTINE MARIE L. NARANJO

Handling Public Prosecutor of RTC Branch 7
Office of the City Prosecutor
2/Floor Department of Justice Bldg.
Department of Agriculture Compound
M. Velez Street, Guadalupe, Cebu City
pros.christinenaranjo@gmail.com
cebucityprosecutionoffice@gmail.com
Received by: ________
Date: _______________