Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

MOTION FOR PERMANENT DISMISSAL

ACCUSED, by the undersigned counsel, unto this Honorable Court, most respectfully states that:

1. On 02 September 2012, an Order was issued by this Honorable Court dismissing the case provisionally with the expressed conformity of the accused. Attached is a copy of the said Order hereto marked as Annex "1" and forms and integral part hereof;

2. Under the Rules on Criminal Procedure, the provisional dismissal of the offenses punishable by imprisonment not exceeding six (6) years, shall become permanent one (1) year after the issuance of the order without the case having been revived;

3. A year had already lapsed, and the prosecution has not instituted any action to revive the case; hence, accused respectfully moves that the case be permanently dismissed.

PRAYER

WHEREFORE, premises considered and in the interest of justice, it is respectfully prayed that the Honorable Court render the case permanently dismissed.

Other reliefs just and equitable are also prayed for.

Imus City, for Pasay City, 29 December 2013.

BAQUIRAN, CORONADO & RICAFRANCA

Counsel for Accused

Jasper Sol Cruz 2nd Floor, RCVJ Building,

Don P. Campa Avenue, Barrio Uno,

2662 Dasmarinas City, Cavite

by:

RAPHAEL ENRIQUE V. CORONADO

Roll No. __________

IBP No. __________/ __________/__________

PTR No. __________/ __________/__________

MCLE Compliance No. __________

Notice

CLERK OF COURT

Regional Trial Court

Branch 21, Imus City

Greetings:

Please submit the foregoing motion for the consideration and approval of the Honorable Court immediately upon receipt hereof.

RAPHAEL ENRIQUE V. CORONADO

Copy furnished:

CLERK OF COURT

Regional Trial Court

Branch 21, Imus City

ATTY. JEFFREY PARIL

1080 Negros Street, Balic- Balic

Sampaloc, Manila

ATTY. ALEXANDER LIQUIGAN

Unit 3C, De Quiroz Bldg.,

Aguinaldo Highway, Perpetual Village,

Palico III, Imus City, Cavite