Romulo Takad: Violation of R.A 6539, Anti-Carnapping Act
Republic of the Philippines
Regional Trial Court
National Capital Judicial Region
Pasig City
People of the Philippines,
Complainant,
-versus-
Criminal Case No. 12345-H
For: Violaltion of R.A 6539
(Anti-Carnapping Act)
Romulo Takad,
Accused.
x--------------------------------------------x
MEMORANDUM
The accused, through counsel, respectfully submits that:
Statement of the case
This case seeks to establish that the accused, Romulo Takad, is guilty beyond reasonable doubt for the violation of Republic Act No. 6539 (AntiCarnapping Act).
Statement of the facts
Prosecution’s Evidence
Romulo Takad is a common law partner of Ma. Teresa Lacsamana, a resident of 374 Villa Street, Palatiw, Pasig City. Ma. The latter is a member of
Page 1 of 10/Violation of R.A 6539/The Pyramid Law Firm
the SCCPPTODA or the SAMAHAN. The SAMAHAN entered into a contract of loan with the BAYAN DEVELOPMENT CORPORATION or the BDC. The BDC is a corporation that extends loans to Sakbayan members and the members of
Tricycle Operators and Drivers Association or TODA. The SAMAHAN obtained a loan from BDC Sakbayan Program, a sum of Php480, 000.00. Each member of the SAMAHAN has a share of Php 80, 000.00 from the said loan. Their contract generally provides that:
“The money loaned by the SAMAHAN form the BDC shall be used to buy a tricycle. They also stipulated that failure of any members of the SAMAHAN to perform their obligations, which is to pay their outstanding debt; their tricycle will temporarily be under the custody of SAMAHAN’s TREASURER. The tricycle will only be released if the member, who failed to pay, pays his/her outstanding debt.”
The accused and Ma. Teresa Lacsamana went to the BDC’s main office.
When they are in the office of the BDC, an employee of BDC, Ms. Zenny
Aguirre, entertained them and released the tricycle. Ma. Teresa Lacsamana registered the said tricycle in her name in the Land Transportation Office of
Pasig City;
Ma.
Regional Trial Court
National Capital Judicial Region
Pasig City
People of the Philippines,
Complainant,
-versus-
Criminal Case No. 12345-H
For: Violaltion of R.A 6539
(Anti-Carnapping Act)
Romulo Takad,
Accused.
x--------------------------------------------x
MEMORANDUM
The accused, through counsel, respectfully submits that:
Statement of the case
This case seeks to establish that the accused, Romulo Takad, is guilty beyond reasonable doubt for the violation of Republic Act No. 6539 (AntiCarnapping Act).
Statement of the facts
Prosecution’s Evidence
Romulo Takad is a common law partner of Ma. Teresa Lacsamana, a resident of 374 Villa Street, Palatiw, Pasig City. Ma. The latter is a member of
Page 1 of 10/Violation of R.A 6539/The Pyramid Law Firm
the SCCPPTODA or the SAMAHAN. The SAMAHAN entered into a contract of loan with the BAYAN DEVELOPMENT CORPORATION or the BDC. The BDC is a corporation that extends loans to Sakbayan members and the members of
Tricycle Operators and Drivers Association or TODA. The SAMAHAN obtained a loan from BDC Sakbayan Program, a sum of Php480, 000.00. Each member of the SAMAHAN has a share of Php 80, 000.00 from the said loan. Their contract generally provides that:
“The money loaned by the SAMAHAN form the BDC shall be used to buy a tricycle. They also stipulated that failure of any members of the SAMAHAN to perform their obligations, which is to pay their outstanding debt; their tricycle will temporarily be under the custody of SAMAHAN’s TREASURER. The tricycle will only be released if the member, who failed to pay, pays his/her outstanding debt.”
The accused and Ma. Teresa Lacsamana went to the BDC’s main office.
When they are in the office of the BDC, an employee of BDC, Ms. Zenny
Aguirre, entertained them and released the tricycle. Ma. Teresa Lacsamana registered the said tricycle in her name in the Land Transportation Office of
Pasig City;
Ma.