Republic of the Philippines
Metropolitan Trial Court in Cities
Branch 1
First Judicial Region
Baguio City
PEOPLE OF THE PHILIPPINES,
- versus - Crim. Case No. 1111
PEDRO JUAN,
Accused.
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APPLICATION FOR PROBATION
ACCUSED, through the undersigned counsel and unto this
Honorable Court, most respectfully applies for probation under the
provisions of Presidential Decree No. 968, as amended by Republic
Act 10707, and states that:
1. On 01 April 2019, accused was convicted of the crime of
Falsification of Commercial document and was sentenced to suffer
imprisonment for one (1) year of prision correccional as minimum to
four (4) years and two (2) months of prision correccional as maximum
and to pay a fine of three thousand pesos (P3,000.00);
2. The crime for which the accused was convicted is not an offense
against national security or public order;
3. Accused has not been previously convicted by final judgment of
any offense punishable by imprisonment of more than six (6) months
and one (1) day and/or a fine of more than one thousand pesos
(P1,000.00);
4. Accused has not been once placed on probation under the
provisions of Presidential Decree No. 968, otherwise known as the
Probation Law of 1976, as amended;
5. Accused has all the qualifications and none of the
disqualifications to avail of the benefits of the Probation Law;
6. Accused is sincerely remorseful of having committed the offense
and if granted probation, he is willing to undergo supervision under
such terms and conditions that may be imposed by the Honorable
Court.
PRAYER
WHEREFORE, premises considered, it is most respectfully
prayed of this Honorable Court that the Application for Probation be
referred to the Parole and Probation Officer of Baguio City for the
requisite post-sentence investigation and thereafter, the application
for probation be approved.
Other reliefs just and equitable in the premises are likewise
sought.
Baguio City, Philippines. April 6, 2019.
ATTY. ALBERT EINSTEIN
Counsel for the Accused
PEDRO JUAN
Applicant
NOTICE OF HEARING
THE BRANCH CLERK OF COURT
MeTC - Branch 1
Baguio City
Greetings!
Please submit the foregoing motion to the Honorable Court on April
26, 2019 at 8:30 in the morning for its favorable consideration and
approval.
ALBERT EINSTEIN
Copy furnished by personal service:
PROSECUTOR ALEXANDER FLEMING
Office of the City Prosecutor, Baguio City
PAROLE AND PROBATION OFFICE
Baguio City