REPUBLIC OF THE PHILIPPINES REGIONAL TRIAL COURT OF LANAO DEL NORTE 12th Judicial Region Branch I Iligan City

PEOPLE OF THE PHILIPPINES, Plaintiff, -versusJUAN DELA CRUZ, Accused. x------------------------------------------/

For: VIOLATION OF SEC.11 ARTICLE II OF R.A. 9165

MEMORANDUM FOR THE ACCUSED

COMES NOW, the accused by the undersigned counsel and unto this Honorable Court, most respectfully submit this Memorandum:

FACTS
That on or before May 1, 2008, in the City of Iligan, Philippines, and within the jurisdiction of this Honorable Court, the said accused, without authority of the law, did then and there willfully, unlawfully and feloniously have in his possession, custody and control 9 plastic sachet of Methamphetamine Hydrochloride weighing more or less 10.25 grams locally known as Shabu.

Contrary to and in violation of Section 11, Article II of Republic Act 9165.

City of Iligan, May 5, 2008.

ISSUES
1. WHETHER OR NOT THE ARREST FOR THE ACCUSED IS VALID;

2. WHETHER OR NOT THE PROCEDURAL REQUIREMENTS OF SECTION 21 WITH RESPECT TO PROCEDURAL AND DISPOSITION OF CONFISCATED DRUGS WERE FOLLOWED. 3.