Republic of the Philippines

Department of Justice
Office of the Provincial Prosecutor
_____________________________

MUNICIPAL SOCIAL WELFARE NPS DOCKET NO. ___________________

AND DEVELOPMENT OFFICE,
_____________________ For: Alleged Violation of
Complainants, Republic Act No.
7610

-versus-

_____________________________,
Respondents.
x- - - - - - - - - - - - - - - - - - - - - - - - -x

MOTION FOR REINVESTIGATION

I , the respondent in the above-entitled case, most respectfully come

before the Honorable Provincial Prosecutor and submitting this Motion for
Reinvestigation, averring thus:

1. On or about _______________________ I received a copy of the

Resolution of the Office of the Provincial Prosecutor regarding the
above-entitled cases, dated October 22, 2010. The dispositive portion of
which stated;

WHEREFORE, it is hereby recommended that the respondent be

charged in court for child abuse under Section 10 (a) of Republic
Act No. 7610.

2. I received the resolution through our previous landlord who informed

me that I had a letter in his possession. Upon receipt of the letter I was
surprised that it contained a resolution which recommended that I be
charged for child abuse.

3. The recommendation was based solely upon the evidence presented

by the complainant on the basis that allegedly I failed to submit my
counter affidavit.

4. In truth, however, the I was never informed of the pendency of the

preliminary investigation as I had not received any subpoena or any
processes from the Office of the Provincial Prosecutor.

5. In fact, it is the resolution of the honorable office which only informed

me that there was a complaint filed against me.

6. In essence I was denied the right to examine the evidence submitted by the
complainant and to present any countervailing evidence that would reverse
finding of probable cause. This is in gross violation of my fundamental
constitutional right of due process.

7. Considering the gravity of the offense being attributed to be me I must be

given the chance and opportunity to examine the evidence submitted by the
complainant and for me to present my defense.
 8. To ensure that I shall receive future notices and subpoena by the honorable
office I voluntary divulge my current address which is in
_________________________, Philippines.

WHEREFORE, premises considered it is most respectfully prayed that the

Honorable Office of the ______________________ to set aside its previous resolution
dated ___________________________ and grant a re-investigation of the above-entitled
case

Done this ______________ day of ___________ at ____________________,

Philippines,

____________________________
Respondent