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IBRAHIM ABBAS
y LINAO,
Accused.
x--------------------------------------x
MOTION TO DISMISS
x x x x x x x x x .
5. In the instant case, the term any crime may refer to the
case of Violation of Sections 11 and 12 of Republic Act No. 9165 which is
filed before this Honorable Court. R. A. 8294 does not state that the
firearm be used in committing another crime in order to extinguish the
crime of illegal possession of firearm. All it states is that the illegal
possession of firearm should not be penalized if committed with another
crime;
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed
of this Honorable Court that after due consideration, the case filed
against herein accused for Violation of PD 1866, as amended by RA
8294, be subsequently dismissed.
Other reliefs just and equitable under the premises are likewise
prayed for.
Department of Justice
PUBLIC ATTORNEYS OFFICE
Manila District Office
4th floor, Godino Building,
350 A. Villegas St., Ermita, Manila
By:
CAROLINE L. TOBIAS
Public Attorney II
NOTICE OF HEARING
Branch Clerk of Court ACP RAUL M. HUSMILLO
RTC Br.17 Rm. 325 Prosecutors Office
Manila Manila
Greetings!