Republic of the Philipppines

Western Visayas Region

REGIONAL TRIAL COURT
Iloilo City, Branch 36

PEOPLE OF THE PHILIPPINES

Complainant,

-versus- For: Grave Threats

Article 282 of the
Revised Penal Code
PEVI MAE FLORES

Accused.

I N F O R M A T I ON

MOTION TO DISMISS

NOW COMES the Accused, by his undersigned attorney, to

this Honorable Court and respectfully moves that the complaint be
dismissed on the ground of lack of jurisdiction under BP. 129.

ARGUMENTS

Batas Pambansa Bilang 129 of the Judiciary Recognization Act

provides for the jurisdiction of courts in the Philippines. The complaint
for the allege commission Grave Threats against, Accused Pevi Mae
Flores, as provided by law, is under the jurisdiction of the Regional
Trial Court in which the Complainant erred by submitting
aforementioned complaint in the Municipal Circuit Trial Court of
Guimbal, Iloilo. This error in the jurisdiction of the casesufficiently
renders the dismissal of the complaint.
 PRAYER

WHEREFORE, Accused, Pevi Mae Flores, respectfully prays

that,the complaint be dismissed.

Iloilo, Philippines January 31, 2015

Atty. Izabella Calzado (SGD)

Counsel for Plaintiff
IBP NO. 7753678/02.03.10/Iloilo
PTR NO. 3636846/01.19.10/Iloilo City
ROLL NO. 504643
MCLE COMPLIANCE NO. II-0015592

Copy Furnish:

Atty. Ben Santos

Counsel for the Defendant
13 Babaw Bldg., Kilid Street
Iloilo City

VERIFICATION

I, ENNA FLEUR C. TRIVILEGIO, of legal age, Filipino, and with

office address at #7 Blumentritt Street, Guimbal, Iloilo, Philippines
after having been sworn into in accordance with law, do hereby
depose and state that:

1. I am the counsel for the Accused in the above-caption Motion to

Dismiss;
2. I have prepared this Motion at the instance and in behalf of the
Accused; and
 3. I have read the same and the contents thereof are known to me
to be true and correct based on my own personal knowledge and
authentic records attached in the Motion itself and made part of
the records of this Case.

IN WITNESS WHEREOF, I hereunto affix my signature this

January 31, 2015 at Iloilo City, Philippines.

IZABELLA CALZADO
Affiant

SUBSCRIBED AND SWORN TO BEFORE ME, this January

31, 2015 at Iloilo City.

Doc. No. _______

Page No. _______
Book No. _______
Series of 2013.