Republic of the Philippines
REGIONAL TRIAL COURT
National Capital Region
Branch 48
City of Manila
THE PEOPLE OF THE PHILIPPINES,
Complainant,
CRIMINAL CASE NO.________________
FOR: Violation of Section 7 of RA 7610
-versus-
MICHAEL JACKSON
Accused.
X – – – – – – – – – – – – – – – – – – – – – – – – – – -X
MOTION TO REDUCE BAIL
UNTO THIS HONORABLE COURT, Accused, through counsel, most respectfully aver:
- That Accused is presently detained at Police Station the City of Manila, pending the hearing of this case, and that this case has been raffled to this honorable court.
- That the Resolution of the Honorable Office of the City Prosecutor has fixed the bail of the accused at Php xx,xxx.xx;
- That the recommended bail for the violation of Section 7 of RA 7610 is Php 200,000.00, in accordance with the 2000 Bail Bond Guide of the Department of Justice National Prosecution Service.
- That accused is not affluent in life and currently have unstable source of income due to the pandemic.
- That the bail recommended is tantamount to the denial of bail. Where the right to bail exists, it should not be rendered nugatory by requiring a sum that is so excessive.
- That accused is asking for the reduction of bail to Php xx,xxx.xx, which amount the accused can raise;
- That accused probability of flight is nil.
- That the accused undertakes to attend all hearings of the instant case whenever his presence is required and duly notified of the same.
WHEREFORE, in view of the foregoing, it is most respectfully prayed that the accused be allowed to post bail for the said case at a reduced CASH BOND of Php xx,xxx.xx.
Other reliefs just and equitable in the premises are likewise sought.
City of Manila, March 21, 2021.
ATTY. LAGING TABLA-TALO
Counsel for the Accused
PTR No. xx-xxxxxxx-x
IBP No. xx-xxxxxxx-x
Roll No. xx-xxxxxxx-x
MCLE Compliance No. xx-xxxxxxx-x
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