1

REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION
METROPOLITAN TRIAL COURT
City of Manila
Branch 9
PEOPLE OF THE PHILIPPINES,
Plaintif,
- Versus 16-CR

Criminal Case Nos. 16-01415For: Violation of B.P. Blg. 22

MICHELLE F. LAPID,
Accused.
X

OMNIBUS MOTION
FOR THE ISSUANCE OF ALIAS WARRANT
AND TO FURNISH THE BUREAU OF IMMIGRATION AND
DEPORTATION (BID) WITH COPY OF THE WARRANT OF
ARREST FOR BID WATCH LIST
COMES NOW, the Private Complainant, in the above
entitled case, by and through the Undersigned Counsel
and unto this Honorable Court, most respectfully avers:
1.
That a warrant for the arrest of the accused has not
been served up to the present;
2. That an Alias Warrant for the Arrest of the accused
should be accordingly issued and be furnished or forwarded to
the Bureau of Immigration and Deportation (BID) for the
inclusion of accused in the BID Watch List;
3.
That there is a paramount need and urgency for the
issuance of an Alias Warrant of Arrest against accused and for
said warrant to be furnished to the Bureau of Immigration and
Deportation.
P R A Y E R
WHEREFORE, premises considered, it is most respectfully
prayed of this Honorable Court that:
a.
This Omnibus Motion be given its due weight and
credence;

b.
An Alias Warrant of Arrest be issued against
Accused;
c.
The Alias Warrant of Arrest be forthwith forwarded
or furnished to the Bureau of Immigration and Deportation at
its Main Office at Immigration Building, Magallanes Drive,
Intramuros, Manila.
Other reliefs and remedies just and equitable under the
premises are respectfully prayed for.
City of Manila, July 21, 2016.

ATTY. LEOPOLDO P. DELA ROSA

Counsel for the Plaintiff
Suite 307 CCI Building
1091 Concepcion Street
Ermita, Manila
I.B.P. No. 3825412/Mla.12-29-2014
P.T. R. No. 4921823/Mla./01-04-2016
Roll No. 28195
MCLE Compliance No. IV-0020667
June 13, 2013
NOTICE
Michelle Lapid
c/o Multiline Marketing Co., Ltd.
No. 44 Sta. Agueda Regency Place Subdivision
Merville, Paraaque City

ACP JEWELLINE JOVETTE B. VALENTON CARREON

Office of the City Prosecutor
City of Manila
Greetings.
Please take notice that Undersigned Counsel will submit the foregoing
Omnibus Motion for the kind consideration and approval of the Honorable Court
on July _____, 2016 at ____________.

ATTY. LEOPOLDO P. DELA ROSA

EXPLANATION
This is to certify as an Officer of the Court that a copy of this OMNIBUS MOTION was
served, not by personal service but by registered mail as herein-below indicated by reason of
time, distance, lack of manpower and urgency.

ATTY. LEOPOLDO P. DELA ROSA

Copy furnished:
Michelle Lapid
c/o Multiline Marketing Co., Ltd.
No. 44 Sta. Agueda Regency Place Subdivision
Merville, Paraaque City

ACP JEWELLINE JOVETTE B. VALENTON CARREON

Office of the City Prosecutor
City of Manila