Republic of the Philippines

____________ Judicial Region

________________ TRIAL COURT

Branch _____, _____________, _____________

MOTION TO ADMIT AFFIDAVIT OF RECANTATION

Respondent, by counsel, respectfully states:

1. That the instant case was assigned for preliminary investigation to Honorable City Prosecutor Jack Miof.

That the complainant voluntarily executed an Affidavit of Recantation assisted by his principal, Rosa Rosal, pertinent portion of which states:

“That after profound review and contemplation, taking into consideration of the facts and circumstances of the above-entitled case, I fully realized that I committed a serious error as to the identity of all the accused and his purported participation in the above-cited case.”

Thus, in the interest of justice, respondent through the undersigned counsel implore this Honorable Office to admit the Affidavit of Recantation as part of the records of this case.

The instant motion is filed in good faith and not meant to delay the proceedings of this case nor prejudice the rights of complainant.

PRAYER

WHEREFORE, premises considered and in the interest of justice, it is respectfully prayed that the Office of the City Prosecutor to admit the Affidavit of Recantation as part of the records of this case.

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