REPUBLIC OF THE
PHILIPPINES
REGIONAL TRIAL COURT
XXX CITY
BRANCH XXX
PEOPLE OF THE
PHILIPPINES,
Plaintiff,
Crim.
Case No. XXX
-
Versus -
For: Violation of
XXX Sec. 3 (e), RA 3019
(Salary Grade 14)
Barangay Chairman
XXX, XXX City,
Accused.
XXX
Barangay Treasurer
XXX, XXX City
XXX
(Salary Grade 10)
Barangay Councilor
c/o Barangay Hall
XXX, XXX City
XXX
(Salary Grade 10)
Barangay Councilor
XXX, XXX City
XXX
(Salary Grade 10)
Barangay Councilor
XXX, XXX City
XXX
Proprietor, XXX
XXX, XXX City,
Accused.
x----------------------------------------x
MOTION TO CONSOLIDATE
TRIALS OF RELATED OFFENSES
(Section 22, Rule 119, Rules of Criminal Procedure[1])
The ACCUSED (1) xxx, (2) xxx, (3)
xxx, (4) xxx, and (5) xxx, by counsel, respectfully move to CONSOLIDATE the trials
of the instant criminal case with the related criminal case now pending in Branch xxx of this Court, under Hon. Xxx, docketed as Criminal
Case No. xxx and entitled “People vs. xxx”
for violation of Section 3 (g) of RA 3019[2],
which is the related criminal case with the lower docket number,
considering that the instant criminal case and the aforecited Criminal Case No.
xxx pending in Branch xxx of this Court “are founded on the same facts”
(Section 22, Rule 119), i.e., the
procurement of vitamins by Barangay xxx of this City which was the subject matter of the one and the same audit report and notice
of disallowance issued by the local office of the Commission on Audit
of this City[3]
and which documents, in turn, became the basis of the subsequent indictment
of the accused by the Office of the Ombudsman.
Xxx City, xxx 2017.
LASERNA
CUEVA-MERCADER
LAW OFFICES
Counsel for Accused xxx, xxxx,
Xxxx, xxx, and xxx
XXX, XXX City
Tel/Fax: XXX
Mobile: XXX
Xxxx
Roll No. XXX, XXX
IBP Lifetime Member No. XXX
IBP XXX Chapter
MCLE Compliance No. XXX, XXX
PTR No. XXX, XXX, XXX City
NOTICE OF HEARING
Branch Clerk of
Court
RTC XXX, XXX City
Office of the City
Prosecutor
Hall of Justice
Xxx City
Prosecution and
Monitoring Bureau
Office of the
Ombudsman
3rd Flr., Ombudsman Annex Bldg.
Agham Rd., Diliman, Quezon City
Mabuhay:
For the convenience and for the economy of
time and expense of all concerned, and with the kind indulgence of the Court,
we shall present the foregoing motion to the Court on xxx, xxx, at 8:30 AM, a previous
setting which has been earlier scheduled by the Court for the preliminary conference of the instant
case. Thank you.
Xxx
xxxx
Copy Furnished:
Office of the City
Prosecutor.
Hall of Justice
Xxx City
(Personal
Delivery)
Prosecution and
Monitoring Bureau
Office of the Ombudsman
3rd Flr., Ombudsman Annex Bldg.
Agham Rd., Diliman, Quezon City
Reg. Rec. No.
Date PO
Presiding Judge
Regional Trial Court
Branch xxx
Hall of Justice
Xxx City
(Personal delivery)
EXPLANATION
A copy hereof is served on the
Office of the Ombudsman via registered mail due to the distance of the office
address of said Office, due to the lack of field staff of undersigned counsel
at this time, and due to the urgency of filing the same.
Xxx
xxxx
[1] “Section 22. Consolidation
of trials of related offenses. — Charges for offenses founded on the same
facts or forming part of a series of offenses of similar character may be tried
jointly at the discretion of the court. (14a).”
[2] Criminal Case No. xxx, PP v. xxx, has
been set for arraignment on xxx at
1:30 PM before Branch xxx of this
Court under Hon. xxx.
[3]
The said COA audit report and notice of disallowance is still under a pending
quasi-judicial appeal before the COA-NCR office prior to the institution of
the two related criminal cases in Branch xxx and Branch xxx of this Court.
