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    Motion To Travel Sample

    Uploaded by

    Charles Villareal
    This document is an urgent motion filed by the accused Hector Thomas Arnaldo Navasero requesting permission from the court to travel abroad. It provides details of the watch list order issued by the court requiring the accused to seek leave before traveling. It specifies the intended destination and dates of travel and assures the court that the accused will abide by any conditions imposed and return on the specified return dates. The motion argues that restricting the accused's right to travel is not warranted as there is no threat to national security, public safety or health. It requests the court grant permission for the accused to travel as specified and provide any other just and equitable relief.

    Copyright:

    © All Rights Reserved

    Motion To Travel Sample

    Uploaded by

    Charles Villareal
    988 views4 pages
    This document is an urgent motion filed by the accused Hector Thomas Arnaldo Navasero requesting permission from the court to travel abroad. It provides details of the watch list order issued by the court requiring the accused to seek leave before traveling. It specifies the intended destination and dates of travel and assures the court that the accused will abide by any conditions imposed and return on the specified return dates. The motion argues that restricting the accused's right to travel is not warranted as there is no threat to national security, public safety or health. It requests the court grant permission for the accused to travel as specified and provide any other just and equitable relief.

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    Sample Of motion to travel

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    Motion to Travel Sample

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    © © All Rights Reserved

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    This document is an urgent motion filed by the accused Hector Thomas Arnaldo Navasero requesting permission from the court to travel abroad. It provides details of the watch list order issued by the court requiring the accused to seek leave before traveling. It specifies the intended destination and dates of travel and assures the court that the accused will abide by any conditions imposed and return on the specified return dates. The motion argues that restricting the accused's right to travel is not warranted as there is no threat to national security, public safety or health. It requests the court grant permission for the accused to travel as specified and provide any other just and equitable relief.

    Copyright:

    © All Rights Reserved
    988 views4 pages

    Motion To Travel Sample

    Uploaded by

    Charles Villareal
    This document is an urgent motion filed by the accused Hector Thomas Arnaldo Navasero requesting permission from the court to travel abroad. It provides details of the watch list order issued by the court requiring the accused to seek leave before traveling. It specifies the intended destination and dates of travel and assures the court that the accused will abide by any conditions imposed and return on the specified return dates. The motion argues that restricting the accused's right to travel is not warranted as there is no threat to national security, public safety or health. It requests the court grant permission for the accused to travel as specified and provide any other just and equitable relief.

    Copyright:

    © All Rights Reserved
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    The document outlines a motion filed by the accused seeking permission from the court to travel abroad for a period of time. It discusses the accused's constitutional right to travel and guarantees they will abide by any conditions imposed by the court.

    The accused is requesting permission from the court to travel abroad to unspecified places on unspecified dates.

    The accused guarantees they will abide by any conditions imposed by the court for their foreign travels and assures the court they will return on the specified return dates and continue abiding by court orders and bail terms.

    REPUBLIC OF THE PHILIPPINES

    REGIONAL TRIAL COURT


    NATIONAL CAPITAL JUDICIAL REGION
    QUEZON CITY
    BRANCH_____

    PEOPLE OF THE PHILIPPINES,


    Plaintiff,
    Criminal Case
    No__________For: Estafa
    HECTOR THOMAS ARNALDO
    NAVASERO,
    Accused.
    x------------------------------------------x

    URGENT MOTION FOR


    PERMISSION/AUTHORITY
    TO TRAVEL ABROAD

    Accused HECTOR THOMAS ARNALDO NAVASERO, by


    counsel, respectfully states that:

    1. On _________, the Honorable Court issued a Watch List


    Order on the Accused in the captioned cases, requiring him to ask for
    leave of court in order to travel abroad.

    2. In this regard, Accused respectfully prays that he be


    allowed to travel to:

    3. Accused will book his tickets and accommodations only


    when the Honorable Court grants this Motion. He undertakes to
    submit to the Honorable Court copies of his bookings once available.
    Accused may be reached anytime through his personal roaming
    mobile number_______.

    4. A copy of the biopage of Accused’s Philippine Passport


    No. ____________ is attached as Annex “A”.

    5. The instant motion is anchored on the Bill of Rights,


    which provides that the constitutional right to travel is a guaranteed
    right which may be impaired only under certain exceptions, to wit:

    1
    “Article III
    Bill of Rights

    SECTION 6. The liberty of abode and of changing the


    same within the limits prescribed by law shall not be
    impaired except upon lawful order of the court. Neither
    shall the right to travel be impaired except in the
    interest of national security, public safety, or public
    health, as may be provided by law.”

    8. With due respect, the instances warranting the restriction


    of Accused’s constitutional right to travel are not availing in this case
    as there is no threat to national security, public safety, or public
    health.

    9. Accused guarantees that he will abide by whatever


    conditions the Honorable Court may impose for his foreign travels.

    10. Moreover, Accused assures the Honorable Court that he


    will return to the country on the return dates specified above, and
    that he will continue to abide by the Orders of the Honorable Court
    and the terms and conditions of his bail.

    11. For the above reasons, Accused humbly requests the


    Honorable Court to allow him to travel abroad to the places and on
    the dates specified above.

    RELIEF

    WHEREFORE, premises considered, it is respectfully prayed


    that the Honorable Court ALLOW the Accused to travel abroad to:

    Accused likewise, prays for other reliefs that may be just and
    equitable under the premises.

    Taguig City for Quezon City, 17 April 2017.

    ANDREW GONZALES
    Collaborating Counsel for the Accused
    2
    8th floor Hanjin Bldg. 1128 38th St. University
    Parkway North Bonifacio Taguig City, 1634, Taguig,
    Roll of Attorneys No.
    IBP No.
    PTR No.
    MCLE Compliance No.

    Copy furnished and notice of hearing:

    Medialdea Ata Bello & Suarez


    Private Prosecutor
    17th Floor, The Taipan Place
    F. Ortigas Jr. Road, Ortigas Center
    Pasig City

    Office of the City Prosecutor


    Quezon City

    Greetings:

    The undersigned counsel shall submit the foregoing Urgent


    Motion for the consideration and approval of this Honorable Court
    on 19 April 2018 at 8:30 a.m. or at the earliest date convenient to the
    calendar of the Honorable Court. This Urgent Motion is being filed
    with the Honorable Court and served upon the Public and Private
    Prosecutor at their last known addresses via personal service.

    ANDREW GONZALES

    3
    Republic of the Philippines)
    ____ City, Metro Manila )

    AFFIDAVIT OF SERVICE

    Affiant CHARLES VILLAREAL, Filipino, legal age, with postal address at 8th
    floor Hanjin Bldg. 1128 38th St. University Parkway North Bonifacio Taguig City,
    1634, Taguig, hereby declares and states that:

    On 17 April 2018 in accordance with Sections 3 and 5 in relation to


    Sections 10 and 11 of Rule 13 of the 1997 Rules of Civil Procedure, Affiant caused
    to be filed by personal service with the Honorable Office copies of the foregoing
    Urgent Motion at the following address:

    Regional Trial Court, Branch 84


    Quezon City

    after furnishing a copy thereof via personal service to:

    Medialdea Ata Bello & Suarez


    Private Prosecutor
    17th Floor, The Taipan Place
    F. Ortigas Jr. Road, Ortigas Center
    Pasig City

    And

    Office of the City Prosecutor


    Quezon City

    IN WITNESS WHEREOF, Affiant has hereunto affixed his signature at


    ____ City, Metro Manila, Philippines, this _____________.

    CHARLES VILLAREAL

    I certify that 17 April 2018, before me, a Notary Public duly authorized in
    Quezon City to take acknowledgment, personally appeared Affiant, exhibiting to
    me his N03-98-253761, who was identified by me through competent evidence of
    identity to be the same person described in the foregoing instrument, who
    acknowledged before me that his signature on the instrument was voluntarily
    affixed by him for the purposes stated therein, and who declared to me that he
    has executed the instrument as his free and voluntary act and deed.

    IN WITNESS WHEREOF, I have hereunto set my hand and affixed my


    notarial seal on the date and at the place above written.

    Doc. No. ____;


    Page No. ____;
    Book No. ____;
    Series of 2018.

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