Motion to Inhibit
Republic of the Philippines
____________ Judicial Region
________________ TRIAL COURT
Branch _____, _____________, _____________
REPUBLIC OF THE PHILIPPINES,
Complainant,
-versus-
______________________,
Accused.
x - - - - - - - - - - - - - - - - - - - - - - - - -x
CRIMINAL CASE NO. _______________
FOR: _________________
MOTION TO INHIBIT
Complainant, by counsel, to the Honorable Court, alleges that:
The instant complaint was filed sometime in 06 May 2011. However, up to this time, no resolution has yet been issued by the honorable office;
This has been the case despite several follow-ups made by the complainant and it is very apparent that there is an unreasonable delay in rendering the resolution to the extreme prejudice of the complainants;
In view of the foregoing, to avoid the appearance of bias and impropriety, it is most respectfully prayed of the Honorable Office that the honorable investigating prosecutor inhibit himself from resolving this criminal complaint.
Other reliefs just and equitable are likewise prayed for.
City of Manila, for Imus City, 25 May 2012.
PARIL LAW OFFICE
Counsel for Private Complainant
1080 Negros Street, Balic- Balic
Sampaloc, Manila
by:
JEFFREY PARIL
IBP#__________, __________Chapter, __________
PTR#__________, __________, __________, __________
Attorney’s Roll No. __________
MCLE Compliance No. II- __________
MCLE Compliance No. III- __________
MCLE Compliance No. IV- __________
Copy Furnished:
PROSECUTOR JACK MIOF
Office of the City Prosecutor
Imus City, Cavite
ATTY. ALEXANDER LIQUIGAN
Unit 3C, De Quiroz Bldg.,
Aguinaldo Highway, Perpetual Village,
Palico III, Imus City, Cavite
ATTY. RAPHAEL CORONADO
2nd Floor, RCVJ Building,
Don P. Campa Avenue, Barrio Uno,
2662 Dasmarinas City, Cavite
Explanation
Copy of the Motion was furnished to the respondent by private courier due to the distance of the undersigned from the said parties, making personal service thereof not practicable.
JEFFREY PARIL