REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

THIRD JUDICIAL REGION
Malolos, Bulacan
Branch ___

PEOPLE OF THE PHILIPPINES,

-versus-

Crim. Case No.000-M-2016

AAA,
Accused.

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

MOTION TO CONSOLIDATE

The Accused, Leonardo Reyes, through the undersigned

counsel, unto this Honorable Court, most respectfully moves for
the consolidation of Crim. Case No. 000-M-2016 pending
before this Honorable Court and Crim. Case No. 001-M-2016
pending before Branch __ of RTC __________, and in support
thereof, states the following:

1. The Accused is being tried for violation of Section 26 in

relation to Section 5 of Article II of R.A. 9165 before this
Honorable Court;
2. The Accused also has a pending case before Branch __
of RTC __________, for violation of Section 11 of Article II
of R.A. 9165 under Crim. Case No. 001-M-2016;

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 3. Both cases arose from the same
facts/event/transaction, involve same issue, and would
depend on the same evidence;
4. Consolidation of criminal cases is permitted under Sec.
22, Rule 119 of the Rules of Court, which states:
Sec. 22. Consolidation of trials of
related offenses. - Charges for offenses
founded on the same facts or forming
part of a series of offenses of similar
character may be tried jointly at the
discretion of the court.
5. Joint trial is proper where the offenses charged are
similar, related, or connected, or are of the same or
similar character or class, or involve or arose out of the
same or related or connected acts, occurrences,
transactions, series of events, or chain of
circumstances, or are based on acts or transactions
constituting parts of a common scheme or plan, or are
of the same pattern and committed in the same
manner, or where there is a common element of
substantial importance in their commission, or where
the same, or much the same, evidence will be
competent and admissible or required in their
prosecution, and if not joined for trial the repetition or
reproduction of substantially the same testimony will be
required on each trial1;
6. The Accused has the right to speedy resolution of his
cases and one of the ways to achieve this is through
the consolidation of his cases. Thus, it is most

1
Neri vs. Sandiganbayan, G.R. No. 202243, August 7, 2013

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 respectfully prayed of this Honorable Court to
consolidate Crim. Case No. 000-M-2016 and Crim. Case
No.001-M-2016 pending before Branch _____ of RTC
_________________________ and that the consolidated
cases be heard and tried before this Honorable Court.

Other reliefs just and equitable are likewise prayed for.

DATE, PLACE.

ATTY. BBB
Counsel for Accused ________________
Address
IBP No.
PTR No.
MCLE Compliance VI
Roll of Attorneys No.

NOTICE

Branch Clerk of Court

Branch ___, Regional Trial Court
_______________________________

GREETINGS:

Please submit the foregoing immediately upon receipt, for the

kind perusal and consideration of the Honorable Court.

BBB

Copy furnished:
Office of the Provincial Prosecutor
_____________________________

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