REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH ____, LAOAG CITY
PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 19275-14
Plaintiff,
-versus- For
MICHAEL UMADAC y Fernandez, Violation of Section 5 of RA 9165
Accused.
X- - - - - - - - - - - - - - - - - - - - - -x
PLEA BARGAINING PROPOSAL
ACCUSED, through the undersigned counsel, unto this Honorable Court
most respectfully states that:
1. Accused is charged of Violation of Section 5, Article II of RA No. 9165;
2. After thorough reflection and with the desire to be with his family the
soonest time possible, accused now intends to change his plea of not guilty
and plead guilty to a lower offense under the acceptable penalty provided for
under Supreme COurt A.M. No. 18-03-16-SC, as follows:
ORIGINAL CHARGE PROPOSAL
Criminal Case No. 19275-14 for Section 12, Article II of RA No. 9165
Violation of Section 5, Article II (Possession of Equipment,
of RA No. 9165 for alleged sale Instrument, Apparatus and Other
of 4.2605 grams of dried Paraphernalia for Dangerous Drugs)
marijuana leaves
3. Accused is willing to undergo Drug Dependency Examination/Drug Test
as a requirement for the approval hereof;
4. In the event that this proposal be approved, accused would readily
withdraw his original plea and will plead guilty under such proposal.
WHEREFORE, premises considered, accused respectfully prays that the
herein plea bargaining proposal be considered by the prosecution and thereafter
approved by the Honorabe Court.
Other reliefs just and equitable under the premises are likewise prayed for.
Respectfully submitted.
Laoag City, Ilocos Norte, Philippines, December 28, 2020.
Atty. ____________________
Counsel for the Accused
Roll No. 80123
IBP Lifetime No. 123456
MCLE Comp. No. VI-0987654/October 13, 2017
Valid until April 14, 2022
At my instance and conformity
MICHAEL F. UMADAC
Accused
REPUBLIC OF THE PHILIPPINES
FIRST JUDICIAL REGION
REGIONAL TRIAL COURT
BRANCH ___, LAOAG CITY
PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 14995-12
Plaintiff,
-versus- for
CHRISTOPHER LAENO CALA MURDER
a.k.a. CHRIS YADAO & CHRIS CALA,
ROBERT BAOIT, DIONY VILLANUEVA,
And ARJAY AGCANAS,
Accused.
X- - - - - - - - - - - - - - - - - - - - - - - - X
PLEA BARGAINING PROPOSAL
ACCUSED ARJAY AGCANAS, through the undersigned counsel, and unto
this Honorable Court most respectfully manifests that:
1. Accused in the above-entitled case is charged with the crime of Murder;
2. Accused wishes to plea bargain with the prosecution by pleading guilty to
the lesser offense of Homicide which is punishable by the penalty of
Reclusion Temporal;
3. Accused prays that the indeterminate penalty of six (6) years and one (1)
day of prision mayor as minimum and twelve (12) years and one (1) day of
reclusion temporal as maximum be imposed.
WHEREFORE, premises considered, it is respectfully prayed that judgment
be rendered finding accused guilty of the crime of Homicide and imposing on him
the indeterminate penalty of six (6) years and one (1) day of prision mayor as
minimum and twelve (12) years and one (1) day of reclusion temporal as
maximum.
Other reliefs just and equitable under the premises are likewise prayed for.
Respectfully submitted.
Laoag City, Ilocos Norte, Philippines, December 28, 2020.
Atty. ____________________
Counsel for the Accused
Roll No. 80123
IBP Lifetime No. 123456
MCLE Comp. No. VI-0987654/October 13, 2017
Valid until April 14, 2022
At my instance and conformity
ARJAY AGCANAS
Accused
