Republic of the PHILIPPINES

REGIONAL TRIAL COURT

9TH Judicial Region
BRANCH 12
Zamboanga City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. 22720

Plaintiff,

-versus- - for –

REYNALDO ROBLES y TUBOG, MURDER

AND TWO (2) UNIDENTIFIED
COMPANIONS,
Accused.
X - - - - - - - - - - - - - - - - - - - -/

MOTION TO REVIVE
AND AMEND INFORMATION

COMES NOW THE PROSECUTION, through the undersigned, most

respectfully moves for the re-opening and revival of the above-entitled

case. In support thereof, it is averred:

1. That the above-entitled case has been archived as accused

was never arrested;

2. Lately, however, private complainant who is the father of the

victim, Police Chief Inspector Edgar Alan Lara Quimiging

appeared before the undersigned with a copy of the Extra-

Judicial Confession of Omar Jakarain Ibno and Abdurahim

Caluang that they perpetrated the killing and brutal murder of

said PCI Quimiging together with was perpetrated by

members of the Abu Sayyaf Group (ASG) owing to the killing

was the information that the Accused reneged on their

settlement and failed to fully comply with her obligation

despite being allowed so much leeway and opportunity. There

is no other recourse but to ask for the cases to be re-opened

and revived in order to protect the interest of the private

complainant.
 WHEREFORE, premises considered and in accordance with Sec.8,

Rule 117 of the Rules of Court, it is respectfully prayed that the above-

entitled cases against Accused be revived and after hearing of this

Motion, the cases be set for the initial

presentation of the evidence for the plaintiff as soon as the Court’s

calendar may permit.

All other reliefs, just and equitable under the premises are

likewise prayed for.

Done this 25th day of April, 2011 in Zamboanga City, Philippines.

IVY FEROLINO DAMAYO

Assistant Regional Prosecutor, Detailed
Trial Prosecutor
MCLE Exemption No. III-000529 dated July 8, 2009

NOTICE OF HEARING

ATTY. NIMFA CARREON-PADAO

Clerk of Court
RTC, Branch 12
Zamboanga City

Madam:

GREETINGS! Please be notified that the undersigned is

submitting the foregoing Motion for the resolution and approval of this
Court immediately upon receipt sans arguments of counsels. Thank
you.

IVY F. DAMAYO

Copy furnished:

ATTY. JOSE MA. D. SAAVEDRA

Counsel for Accused
Zamboanga City