Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
BRANCH 23
General Santos City

THE PEOPLE OF THE PHILIPPINES Crim. Case No. 26879

Plaintiff,
-for-

Violation of Section 18(a) & 19(a) in

-versus- relation to Section 22(a) & punished
under Section 28(e) of the SS Law
(RA 1161), as amended by RA 8282.

NOLI CAJUTOL, JUDITO EBALLE,

JOCELYN T. BERMUDEZ, CELIA
MONTANO, CSAR ERIBAL, ALBERTO
DEJOS & ALBERTO TAMAYO,
Accused.
x - - - - - - - - - - - - - - - - - - - - - - - -x

MOTION TO WITHDRAW INFORMATION

Complainant SOCIAL SECURITY SYSTEM (SSS), by the

undersigned counsel and unto this Honorable Court most respectfully states
that:

1. An Information was filed against all of the accused before this

Honorable Court for violation of Sections 18(a) and 19(a) in
relation to Section 22(a) of Republic Act 1161 as amended by
RA 8282, otherwise known as the Social Security Act of 1997
punishable under Section 28(e) thereof;

2. All of the accused have already posted bail after a warrant for
their arrest was issued and we have yet to receive a notice for
their arraignment; and

2. Immediately after the filing of the Information, complainant

SSS discovered new evidence with regard to the liability of all
the accused that would warrant reinvestigation of this case;

3. As such, we find the need to withdraw the Information due to

1. People versus Noli Cajutol, et. al., Crim. Case No. 26879.
 discovery of supervening facts that would affect the original
findings as to the existence of probable cause against all of the
accused.

WHEREFORE, in the interest of justice, it is most respectfully

prayed of this Honorable Court that the Information of the above entitled
case be ordered withdrawn and this case be remanded to the City
Prosecution Office for reinvestigation.

Respectfully submitted.

May 13, 2016, General Santos City, Philippines.

Atty. Voltaire P. Agas

Atty. Renato J.S. Cuisia
Atty. Gil P. Garcia
Atty. Zavier A. Palao
Counsels for the SSS
SSS, Bajada, Davao City
By:

ZAVIER A. PALAO
Roll No. 53365
PTR No. 6612185,01.11.16, G.S.C
IBP OR No. 1013355,01.11.16,G.S.C
TIN 906-869-362
MCLE Compliance No.V-0008203,6/18/15

Conforme:

PROS. JEROME C. BEATISOLA

Handling Prosecutor
City Prosecutor's Office
General Santos City

With Approval:

PROS. SALAHUDDIN M. SERAD

Sr. Assistant Regional Prosecutor
Officer-In-Charge
City Prosecutors Office
General Santos City

2. People versus Noli Cajutol, et. al., Crim. Case No. 26879.
 REQUEST

THE CLERK OF COURT

Regional Trial Court
Branch 23
General Santos City

Greetings:

Please submit the foregoing Motion for the kind consideration of the
Honorable Court sans oral argument and appearance of the undersigned
counsel.

ATTY. ZAVIER A. PALAO

Copy furnished:

NOLI CAJUTOL
JUDITO EBALLE,
JOCELYN T. BERMUDEZ,
CELIA MONTANO,
CESAR ERIBAL,
ALBERTO DEJOS &
ALBERTO TAMAYO,
Sarangani Fruit Workers Multi Purpose Cooperative
Sitio Alcantara, Datal Tampal, Malandag
Malungon Sarangani Province
Registered Mail No.______________
Date Mailed ____________________

EXPLANATION

All of the accused are furnished a copy of this Motion through

registered mail due to distance.

ATTY. ZAVIER A. PALAO

3. People versus Noli Cajutol, et. al., Crim. Case No. 26879.