Republic of the Philippines

First Judicial Region

REGIONAL TRIAL COURT
BRANCH 26
San Fernando City, La Union

PEOPLE OF THE PHILIPPINES,

CRIM.CASE NO. 11358
Plaintiff,
for
- versus -
VIOLATION OF REPUBLIC ACT
MICHAEL PADILLA y Mon ,
NO. 10591
Accused.
x---------------------------x

MOTION TO RELEASE ACCUSED FROM

DETENTION
ACCUSED through the undersigned Public Attorney and unto this
Honorable Court, most respectfully avers that:

1. Last August 10, 2018, accused pleaded guilty to the lesser offense of
Violation of Sec. 31 of Republic Act No. 10591 and subsequently, the
Honorable Court handed down its verdict convicting the accused for
the said offense and imposing a penalty of imprisonment for one (1)
year;

2. Accused is presently detained at the San Fernando City Jail of the

Bureau of Jail Management and Penology (BJMP) for the above-
captioned case;

3. As of today, January 23, 2019, accused has been in detention for 7

months and 16 days. He just needs 4 ½ months to complete the service
of his sentence but because of his good conduct at the San Fernando
City Jail, he has earned for himself an additional of 150 days credit.
This 150 days credit should be counted as part of the service of his
prison term imposed upon him by the Honorable Court pursuant to
Republic Act No. 10592. Copy of the Certificate of Good Conduct Time
Allowance as well as the Certificate of Detention of accused issued by
BJMP Jail Warden of the San Fernando City Jail, JSUPT LORETA O.
PALADA, dated January 23, 2109 is hereto attached as Annex “A” and
series for reference; and

4. With the 150 days credit equivalent to 5 months earned by the accused,
accused is deemed to have served his sentence in the above-captioned
cases.
Motion to Release Accused from Detention
Crim. Case No. 11358
Page 1 of 2
 WHEREFORE, premises considered, it is most respectfully prayed of
this Honorable Court to issue an order releasing the accused MICHAEL
PADILLA y Mon from detention for having served the sentence imposed on
him by the Honorable Court on the above-captioned case.

Other just and equitable reliefs under the premises are likewise prayed
for.

RESPECTFULLY SUBMITTED this February 11, 2019 at San Fernando

City, La Union, Philippines.

PUBLIC ATTORNEY’S OFFICE

San Fernando City (LU) District Office
Counsel for the Accused
Justice Hall, Sevilla
San Fernando City, La Union
By:

GILBERT R. HUFANA
Public Attorney II
Roll No. 61392; March 27, 2012; Manila
IBP Lifetime No. 018981; IBP-La Union Chapter
MCLE Compliance No. V-0002509; May 29, 2014

NOTICE OF HEARING

The Branch Clerk of Court

RTC Branch 26
San Fernando City, La Union

Greetings! Please submit the foregoing MOTION TO RELEASE

ACCUSED FROM DETENTION for the consideration and approval of the
Honorable Court immediately upon receipt hereof.

GILBERT R. HUFANA

Copy furnished:

PROS.MARILEX CABADING
OFFICE OF THE CITY PROSECUTOR
Justice Hall, Sevilla, San Fernando City, La Union

Motion to Release Accused from Detention

Crim. Case No. 11358
Page 2 of 2