Republic of the Philippines

DEPARTMENT OF JUSTICE
Office of the City Prosecutor
Cebu City

juana dela crux, NPS DOCKET NO. X1-02-INV-19-C-

1194
Complainant
-versus-
For: VIOLATION OF R.A
No. 7610
ching ba ching
Respondents,
x-----------------------------------------------x

VERIFIED MOTION FOR RECONSIDERATION

RESPONDENTS, through the undersigned counsel, move

this Honorable Office for a reconsideration of its Resolution
dated July 4, 2019, a copy of which was received on July _,
2019 upon the following considerations and further avers
that:

1. The Respondents received the Resolution of the

Office of the City Prosecutor on July 19, 2019;

2. Upon learning of the said resolution, the Respondents

were surprised for they were not able to receive the
Affidavit-Complaint filed by the complainant;

3. The Respondents should have been given the chance

to file their respective counter-affidavits in order to
answer the allegations of the complaint;
 4. The Resolution would have been resolved differently
should the respondents be given the chance to file
their respective counter-affidavits;

5. Herein Respondents are submitting their respective

Counter-Affidavits to answer the allegations in the
Affidavit-Complaint. Attached herewith are the
Counter-Affidavits of the Respondents;

PRAYER

IN VIEW OF THE FOREGOING, it is respectfully prayed of

this Honorable Office that the Resolution, dated July 04,
2019, recommending for the filing of an information for
Slight Physical Injury under Article 266, Par. 1, of the Revised
Penal Code against herein Respondents be REVERSED and
SET ASIDE, and that a Resolution be issued DISMISSING the
Complaint.
Other reliefs, just and equitable in the premises, are
likewise prayed for.

RESPECTFULLY SUBMITTED.

Davao City, Philippines. __________.

NOTICE OF SUBMISSION

Administrative Officer
City Prosecution Office
__________________________

Please take notice that we are submitting the foregoing

Motion for the kind consideration of this Honorable Office
immediately upon receipt hereof sans appearances and
without further arguments.

Thank you.

Copy furnished:

VERIFICATION
 Republic of the Philippines)
Davao City )S.S.
x-------------------------------------------x

AFFIDAVIT OF SERVICE

I, ______________, of legal age, and with office address at

_______________________________________________________,
Philippines, after having been duly sworn to in accordance with
law, depose and state:

1) I am a staff of ______________________, Counsel for the

Respondent, ___________________________________, in
the above-entitled case;

2) ______________________, I served a Motion for

Reconsideration by registered mail pursuant to Section 7,
Rule 13 of the Rules of Court to:

IN WITNESS WHEREOF, I have hereunto set my hand

_________________________________

___________________
Affiant

SUBSCRIBED AND SWORN to before me this

______________________ at Davao City, Philippines; Affiant exhibiting
to me _______________________________.

Doc. No. ____;

Page No. ____;
Book No. ____;
Series of 20___.