Republic of the Philippines
MUNICIPAL TRIAL COURT IN CITIES
9th Judicial Region
BRANCH 4, Zamboanga City
PEOPLE OF THE PHILIPPINES
- Plaintiff,
Criminal Case No. 58269
- for -
- versus QUENIE GABUYAN TEODORO
a.k.a. “Quenie Amil y Tesoro”
- Accused.
x- - - - - - - - - - - - - - - - - - - - - - - - -x
Reckless Imprudence resulting
to Homicide
APPLICATION FOR PROBATION
COMES NOW ACCUSED, through undersigned counsel, unto this
Honorable Court, most respectfully applies for probation under the provisions
of Presidential Decree No. 968 as amended and states that:
1. On January 5, 2024, herein Accused was convicted of the crime of
Reckless Imprudence resulting to Homicide as defined under Article 365 of
the Revised Penal Code, and taking into consideration her spontaneous plea
of guilty as a mitigating circumstance, is hereby sentenced to suffer a straight
penalty of imprisonment of eight (8) months of prision correccional;
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 not less than one month and one day
and/or fine of not less than two hundred pesos;
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.
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 Zamboanga City for the requisite postsentence investigation and thereafter, the application for probation be
approved.
Other reliefs just and equitable in the premises are likewise sought.
Zamboanga City, Philippines. September 19, 2013.
Atty. ELPIDIO F. NUVAL
Counsel of Petitioners
CERILLES, NAVARRO, NUVAL & GO LAW OFFICES
E-39 Plaza Pilar, Pettit Barracks, Zamboanga City
PTR No. 2629080; ZC; 03-28-2023
IBP No. 317622; ZC; 03-13-2023
Roll of Attorney No. 30557
MCLE Compliance No. VI-0025474
NOTICE OF HEARING
THE BRANCH CLERK OF COURT
MTCC - Branch 4
Zamboanga City
Greetings!
Please submit the foregoing motion to the Honorable Court on January
12, 2024 at 8:30 in the morning for its favorable consideration and approval.
Atty. ELPIDIO F. NUVAL
Copy furnished by personal service:
The City Prosecutor
Office of the City Prosecutor
Hall of Justice, Zamboanga City
PAROLE AND PROBATION OFFICE
Hall of Justice, Zamboanga City
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