Motion To De-Archive and Revive
Motion To De-Archive and Revive
PEOPLE OF THE
PHILIPPINES,
Plaintiff CRIM. CASE No.
-versus- R-DVO-10-01109-CR
PATRICK N. MANALO, FOR:
Accused. ESTAFA
x---------x
states that:
accused with this Court and with the Office of the City Prosecutor
2. For the record, the real and address of the Accused at that time
was (and still is): “No. 435-C Bonifacio Street, Davao City.”
Page 1 of 7
3. Since June of 2016 the ACCUSED has been paying on installments
month of December, which was the last time that said JEFF
before this Honorable Court. The said ANA COMDA showed the
was from ANA COMDA that the Accused had learned that JESS
subject matter of the instant case, was a regular loan that he had
secured from JESS PIZO without malice or bad faith, and that the
Page 2 of 7
said loan was in fact being religiously paid by him on
thereon in behalf of JESS PIZO from the Accused since June 2016.
scouted for a private lawyer that he could later hire to assist him
Court and from the Office of the City Prosecutor so that the
Ms. Prima Vena, visited the Court and the Office of the City
8. His undersigned counsel has learned that the Court had archived
the instant case in December 16, 2017 due to the inability of the
Page 3 of 7
local PNP Police Station of Davao City to arrest him, per a
Court and to post bail to face the trial of the instant case.
2. The trial court is Regional Trial Court, Branch 17, 11th Judicial
3. The new lady judge is Judge Mary C. Josol. The clerk of court of
the court is Atty. Jackie Santos. Its tel. no. is 082 297 7845.
Page 4 of 7
8. According to the resolution of the fiscal, the amount involved is
If you wish to hire our law office to be your defense counsel, please
set an appointment (a) to discuss the case and (b) discuss our
10. The accused is very much willing, able and ready to post a BAIL
the trial of this case and clear his good name as a family man and
a businessman.
11. For the above purpose, there is an urgent need for an Order
calendar the case and act on the prayer of the Accused to post
and a businessman.
Page 5 of 7
12. This motion is VERIFIED to serve as the Affidavit of Merit of the
above.
FURTHER, the Accused respectfully prays for such and other reliefs as
Philippines.
Greetings:
Please take notice that the undersigned counsel for the accused hereby
earnestly requests that the foregoing Motion to De-Archive and Revive
be included in the calendar of cases to be heard by this Honorable
Court, on January 18, 2020, at 1 o’clock in the afternoon.
Thank you.
Page 7 of 7