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

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    Mc Go
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    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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    Motion

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    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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    27 views2 pages

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

    Uploaded by

    Mc Go
    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.

    Copyright:

    © All Rights Reserved
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    of 2

    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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