Professional Documents
Culture Documents
DAVE L. MENDOZA,
Accused.
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MOTION TO QUASH INFORMATION
Accused, by his undersigned attorney, respectfully moves to quash the
information filed against him on the ground that:
The court trying the case has no jurisdiction over the person of the
accused as the arrest was illegal.
I
MATERIAL ANTECEDENT FACTS
1.1 Sometime on 7 November 2014, PS/INSP Juan S. Cruz of Surigao
City Police Station, Surigao City, filed an Application for Search Warrant
with the Regional Trial Court, Branch 2, Butuan City;
1.2 To justify his application of a Search Warrant to be implemented
outside the court's territorial jurisdiction, the applicant claimed that That thereafter, I decided to apply a Search Warrant to the Regional
Trial Court, Libertad, Butuan City for the compelling reasons that
subject respondent is an active PNP member who has more connections
and friends in RTC, Surigao del Norte and City and other government
agency, in which, I could not divulged their names for confidentiality
and security reason and this could be compromise in our operation...
1.3 Finding probable cause therefor, the Regional Trial Court, Branch 2,
Butuan City, issued Search Warrant No. 1234-2014 which authorized the
COPY FURNISHED:
THE BRANCH CLERK OF COURT
Regional Trial Court
10th Judicial Region
Surigao City, Branch 31
THE HONORABLE ASSISTANT PROVINCIAL PROSECUTOR
Office of the Provincial Prosecutor
Hall of Justice, Surigao City
NOTICE OF HEARING
Please take notice that on Tuesday, 20 January 2015, at 2:00 oclock in
the afternoon or thereabouts, or as soon as this may be calendared for
hearing, the undersigned counsel will submit the foregoing Motion for the
consideration and approval of this Honorable Court.
RALNA DYAN T. FLORANO
COPY FURNISHED:
THE BRANCH CLERK OF COURT
Regional Trial Court
10th Judicial Region
Surigao City, Branch 31
THE HONORABLE ASSISTANT PROVINCIAL PROSECUTOR
Office of the Provincial Prosecutor
Hall of Justice, Surigao City