Republic of the Philippines

REGIONAL TRIAL COURT

NATIONAL CAPITAL JUDICIAL REGION
Branch __, Manila

PEOPLE OF THE PHILIPPINES

Plaintiff,
CRIM. CASE No.___
-versus- For: FALSIFICATION OF
PUBLIC DOCUMENTS

JUAN DELA CRUZ,

Accused.

x-----------------------------------x

MOTION TO SUSPEND ARRAIGNMENT

COMES NOW, the accused, through the undersigned

counsel and unto this Honorable Court, respectfully avers
that:

(1) The above-entitled case is set for arraignment on

December 2, 2017, at 8:30 a.m.;

(2) The said accused filed a Petition for Review of the

Resolution of the City Prosecutor of Manila and now
pending before the Department of Justice. Copy of the
Petition for Review is hereto attached as Annex 1
hereof;

(3) Invoking the provision of Sec. 11, Rule 16 of the

Revised Rules on Criminal Procedure, accused most
respectfully moves that the scheduled arraignment of
 the above-entitled case be suspended until the final
resolution of the accused Petition for Review with the
DOJ;

(4) That this motion is not intended to delay the

proceedings of this case but for the protection of the
rights and interest of the parties herein.

WHEREFORE, it is most respectfully prayed of this

Honorable Court that an Order be issued deferring the
scheduled arraignment on December 2, 2017, or suspend
the proceedings of the case until the termination of the
accused Petition for Review with the DOJ.

Such other relief and remedies as may be deemed just

and equitable under the premises are likewise prayed for.

Manila, 26 December 2017.

SANTOS REYES AND ESTRADA

LAW OFFICE
Counsel for the Accused
3/F Fedman Suites
Salcedo Village, Makati City

By:
MARTIN B. SANTOS
IBP NO. 610084/3-5-16/Mkt
PTR No. 3114535/3-8-16/Mkt
MCLE Compliance No. VI
Roll No. 34839
 NOTICE OF HEARING

To: 1) THE HON. TRIAL PROSECUTOR

2) THE BRANCH CLERK OF COURT
RTC, BR. 139, Makati

GREETINGS:

Please submit the foregoing MOTION TO SUSPEND

PROCEEDINGS for the consideration and approval of the
Honorable Court on 2 December 2017, at 8:30 A.M.

MARTIN B. SANTOS

Copy furnished:

1) Office of the City Prosecutor of Makati

17th Floor, Makati City Hall
Brgy. Poblacion, Makati City

2) JOSE REYES
#30 Catmon St., San Antonio
Makati City, M.M.

(EXPLANATION OF SERVICE)

I HEREBY EXPLAIN that I have furnished the other

parties copy of the foregoing pleading by registered mail owing to
the distance of said counsels office.

MARTIN B. SANTOS