Memorandum Finals
Content
Republic of the Philippines
REGIONAL TRIAL COURT
Judicial Region 5
Branch No. 1234
Quezon City
SAMUEL DECIMO
Petitioner,
Crim Case No. 01-23456
For: Article 248 Murder
-versus-
PEOPLE OF THE REPUBLIC OF THE PHILIPPINES,
Respondents,
INFORMATION
The undersigned Assistant Prosecutor, upon sworn complaint originally filed by the
offended party, accuses Samuel Decimo of the crime of MURDER, committed as follows:
That on or about September 7 in the city of Cavite, Philippines within the jurisdiction of
this court, the said accused, did then and there, with malice and with deliberate intent to take the
life of Kaye Davantes, willfully, unlawfully, feloniously, suddenly, unexpectedly, and
treacherously strangling the victim with the latter’s cable of her laptop computer.
thereby causing the direct and immediate death.
I. The Parties
1. Petitioner
2. RESPONDENT is …. ..
Cause of Action
PRAYER
WHEREFORE, presmises considered, it is respectfully prayed that this
Honorable Court:
1. ISSUE a Temporary Environmental Protection Order (TEPO)
immediately upon filing of this petition, ordering TRI to refrain from taking
any action pursuant to the project;
2. DIRECT TRI to permanently cease and desist from further conducting
pyrolysis operations within the facility;
3. DIRECT TRI to conduct clean-up operations within the area where it
dumped its waste;
4. ISSUE a Writ of Continuing Mandamus ordering DENR to execute its
order to permanently shut down the TRI pyrolysis facility until the same is
satisfied;
5. Render judgment in in favor of the Petitioner by entitling it to
judgment against Respondents for all such sums adjudged in favor of
Petitioner.
Petitioners pray for such other reliefs which relate to the right of the
people to a balanced and healthful ecology or to the protection,
preservation, rehabilitation or restoration of the environment.
Contrary to law.
(Venue, date)
Assistant City Prosecutor
Witnesses:
BAIL RECOMMENDED:
Certification
Dude, ikaw na bahala sa rest
REGIONAL TRIAL COURT
Judicial Region 5
Branch No. 1234
Quezon City
SAMUEL DECIMO
Petitioner,
Crim Case No. 01-23456
For: Article 248 Murder
-versus-
PEOPLE OF THE REPUBLIC OF THE PHILIPPINES,
Respondents,
INFORMATION
The undersigned Assistant Prosecutor, upon sworn complaint originally filed by the
offended party, accuses Samuel Decimo of the crime of MURDER, committed as follows:
That on or about September 7 in the city of Cavite, Philippines within the jurisdiction of
this court, the said accused, did then and there, with malice and with deliberate intent to take the
life of Kaye Davantes, willfully, unlawfully, feloniously, suddenly, unexpectedly, and
treacherously strangling the victim with the latter’s cable of her laptop computer.
thereby causing the direct and immediate death.
I. The Parties
1. Petitioner
2. RESPONDENT is …. ..
Cause of Action
PRAYER
WHEREFORE, presmises considered, it is respectfully prayed that this
Honorable Court:
1. ISSUE a Temporary Environmental Protection Order (TEPO)
immediately upon filing of this petition, ordering TRI to refrain from taking
any action pursuant to the project;
2. DIRECT TRI to permanently cease and desist from further conducting
pyrolysis operations within the facility;
3. DIRECT TRI to conduct clean-up operations within the area where it
dumped its waste;
4. ISSUE a Writ of Continuing Mandamus ordering DENR to execute its
order to permanently shut down the TRI pyrolysis facility until the same is
satisfied;
5. Render judgment in in favor of the Petitioner by entitling it to
judgment against Respondents for all such sums adjudged in favor of
Petitioner.
Petitioners pray for such other reliefs which relate to the right of the
people to a balanced and healthful ecology or to the protection,
preservation, rehabilitation or restoration of the environment.
Contrary to law.
(Venue, date)
Assistant City Prosecutor
Witnesses:
BAIL RECOMMENDED:
Certification
Dude, ikaw na bahala sa rest
