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Branch 74 People of The Philippines) ) ) - Versus-) ) For: Viol. of Section 5) RA 9165) ) PPPPP) ) X - X

This supplemental motion requests that the court accept the results of a mandatory drug test conducted by PDEA on the accused and other detainees as sufficient compliance with the court's order to assess the accused for drug dependency. The motion details that the accused tested negative for drugs in the PDEA-administered test on August 31, prior to the original motion filing. It provides the drug test report and asks the court to consider this as meeting the order's requirements.

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80 views2 pages

Branch 74 People of The Philippines) ) ) - Versus-) ) For: Viol. of Section 5) RA 9165) ) PPPPP) ) X - X

This supplemental motion requests that the court accept the results of a mandatory drug test conducted by PDEA on the accused and other detainees as sufficient compliance with the court's order to assess the accused for drug dependency. The motion details that the accused tested negative for drugs in the PDEA-administered test on August 31, prior to the original motion filing. It provides the drug test report and asks the court to consider this as meeting the order's requirements.

Uploaded by

Mc Go
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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1

Republic of the Philippines


Fourth Judicial Region
REGIONAL TRIAL COURT
ANTIPOLO CITY
BRANCH 74

PEOPLE OF THE PHILIPPINES )


Plaintiff, )
)
-versus- )CRIM CASE NO. 10-39449
)For: Viol. Of Section 5
)RA 9165
)
)
PPPPP )
Accused. )
x-----------------------------------------------x

SUPPLEMENTAL
MOTION TO PLEA BARGAIN

Accused, PPPPP, through the undersigned counsel de officio,


to this Honorable Court, most respectfully moves and states that:

1. On 17 September 2018, accused through counsel filed his


“Motion to Plea Bargain” [ Motion for brevity) dated 13 September
2018 in the above entitled;

2. Acting on the said Motion, the Honorable Court directed


the Jail warden of Cainta Municipal Jail, [where accused is currently
detained] to subject the accused to undergo drug dependency/ drug
test at Marikina City Health Center Drug testing Laboratory Office,
Marikina, within 48 hours from receipt of the Order issued by the
Honorable court for that purpose;

3. Recently, undersigned was informed that prior to the


filing of the instant Motion, accused together with all detainees of
Cainta Municipal Jail, including all personnel of Cainta Municipal
Jail, in coordination with the local government of the Cainta, were
subjected to mandatory drug test last August 31, 2018 duly
administered by the Philippines Drug Enforcement Agency (PDEA);

4. In fact, September 4, 2018, the Cainta Municipal Jail


through the Jail Warden received a copy of the Chemistry Report No.
PDEA- MDTBJMPCAINTA018-FEMALE-001f to 102F duly
issued by Forensic Chemist of PDEA, wherein herein accused, all
other detainees as well as CMJ’s personnel were found to be
2

NEGATIVE, to the presence of any dangerous drugs. Copy of the


Chemistry Report is hereto attached as Annex “A” and “A-1”
( highlighted portion) and made form part of this
supplemental motion;

5. The conduct of the mandatory drug test was done, 17


days, more or less prior to the filing of the Motion, thus, in all intents
and purposes, shall be equated to the compliance of the drug
dependency assessment as required by the under A.M. 18-03-16-SC 1
and Department Circular No. 0272 dated June 26, 2018;

6. For this reason, and considering that the drug test


conducted for accused Samin yielded a NEGATIVE result, accused
through the undersigned counsel most respectfully moves that the
drug test result and/or Chemistry Report attached in this
Supplemental Motion be considered as a sufficient and/or substantial
compliance of the Order dated 21 September 2018, directing the Jail
warden to subject herein accused for drug dependency assessment
and/or drug test;

7. This motion is done in good faith and not intended to disturb


the orderly procedure of the Honorable Court but solely based on the
afore-stated reason.

PRAYER

WHEREFORE, premises considered, it is most respectfully


prayed of this Honorable Court that the mandatory drug test
conducted by PDEA which yielded a NEGATIVE result and the
attached Chemistry Report be considered as sufficient and/or
substantial, compliance to the Order dated 21 September 2018
directing the Jail warden to subject herein accused for drug
dependency assessment and/or drug test.

Other reliefs just and equitable under the premises are likewise
prayed for.

Antipolo City, 1 October 2018.

1
Adoption of the Plea Bargaining Framework in Drug Cases
2
Amended guidelines on Plea Bargaining for Republic Act No. 9165, otherwise known as the
“Comprehensive Dangerous Drugs Act of 2000”

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