Professional Documents
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upon the filing of a petition for certiorari with this Court
questioning the propriety of the issuance of the abovementioned resolutions. Due respect for the Supreme Court
and practical and ethical considerations should have
prompted the appellate court to wait for the final
determination of the petition before taking cognizance of the
case and trying to render moot exactly what was before this
court.
5.
Verily, so as not to render moot the issues raised before the Court of
Appeals in the petition for habeas corpus and for practical and ethical considerations,
this Honorable Court should wait for the final determination of the said petition before
taking cognizance of the case.
PRAYER
WHEREFORE, premises considered, it is respectfully prayed that the Honorable
Court suspend the proceedings in this case including the arraignment of all the accused
and wait for the final determination of the petition for habeas corpus.
Other reliefs and remedies just and equitable under the premises are likewise
prayed for.
Angeles City for the City of San Fernando, Pampanga, 7 June 2011.
Atty. SASHIMI DE JESUS
Counsel for the Accused
Sps. Katsudon and Teriyaki Valencia
Roll of Attorneys No. 11111
IBP Lifetime Member No. 00222
PTR No. AC3333333/01-03-2013
MCLE Compliance No. IV-4444444
Issued on December 12, 2012
555 Sto. Entierro St., Angeles City
Tel Nos. 888-6666, 888-7777
NOTIFICATION AND COPY FURNISHED:
MAGURA TOLENTINO, JR.
City Prosecutor
City of San Fernando
Pampanga
The Branch Clerk of Court
MTC Branch III
City of San Fernando
Pampanga
Greetings:
Please submit the foregoing for the consideration and resolution of the Honorable
Court immediately upon receipt hereof.
Atty. SASHIMI DE JESUS
EXPLANATION
(in compliance with Section 11, Rule 13 of the 1997 Rules of Civil Procedure)
Copies of the pleading/motion to which this explanation is appended was:
sent to counsel for the adverse party/ies by registered mail; due to the
following reason/s:
the distance between this Honorable Court and counsels office which
makes personal filing of the pleading/motion impracticable;
the great distance from the office of counsels for the parties which makes
personal service impracticable;
time constraints.
Atty. SASHIMI DE JESUS