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Motion To Reduce Bai

The document is a motion filed in a criminal case in the Regional Trial Court of Davao City to reduce the bail amount set for the accused, Ramony Ramona. The motion argues that (1) the recommended bail of 20,000 pesos for the crime of estafa is excessive given accused's financial means as a minimum wage employee, (2) the recommended bail amount is tantamount to a denial of bail, and (3) accused is asking for a reduced bail of 10,000 pesos which they can afford. The motion also notes accused is a good community member, unlikely to flee, and has no prior convictions or pending cases. The motion requests the court allow accused to post bail of 10,000

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Paulo Villarin
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272 views3 pages

Motion To Reduce Bai

The document is a motion filed in a criminal case in the Regional Trial Court of Davao City to reduce the bail amount set for the accused, Ramony Ramona. The motion argues that (1) the recommended bail of 20,000 pesos for the crime of estafa is excessive given accused's financial means as a minimum wage employee, (2) the recommended bail amount is tantamount to a denial of bail, and (3) accused is asking for a reduced bail of 10,000 pesos which they can afford. The motion also notes accused is a good community member, unlikely to flee, and has no prior convictions or pending cases. The motion requests the court allow accused to post bail of 10,000

Uploaded by

Paulo Villarin
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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Republic of the Philippines

REGIONAL TRIAL COURT


11th
Judicial Region
Branch 23
Davao City

THE PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO.2323


Complainant, FOR: ESTAFA

-versus-

RAMONY RAMONA
Accused.
X-------------------------
--X

MOTION TO REDUCE BAIL

UNTO THIS HONORABLE COURT, Accused, through counsel, most


respectfully aver:

1. That Accused is presently detained at Talomo Police Station,


Davao City, pending the hearing of this case, and that this case
has been raffled to this sala;

2. That the Resolution of the Honorable Office of the City


Prosecutor has fixed the bail of the accused at P20,000.00;

3. That the recommended bail for the offense of Estafa is


P6,000.00, in accordance with the 2000 Bail Bond Guide of the
Department of Justice National Prosecution Service;

4. That accused is not affluent in life, being a mere employee


with minimum wage;

5. 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.

6. That accused is asking for the reduction of bail to P 10,000,


which amount the accused can raise;
7. That accused is a good member of the community, and a
resident of Davao City, and the probability of flight is nil;

8. That accused has not been previously convicted of any crime


and have no pending case in any judicial or quasi-judicial body
in the Philippines.

9. That accused will undertake to be present when this case is


called in Court.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed that


the Honorable Court will allow accused to post bail in the amount of P
10,000.00 for his provisional liberty during the pendency of this case.

Davao City, Philippines, March 12, 2020.

By:

ATTY. PAULO JOSE S. VILLARIN


Roll of Attorneys No. 696969
PTR No. 69669, 4-24-20, Davao City
IBP No. 5559, 4-24-20, Davao City
MCLE Compliance No. VII-0220293; 4-19-19
Valid until April 14, 2022
Ecoland, Davao City

NOTICE OF HEARING

CITY PROSECUTION’S OFFICE


_____________________

CLERK OF COURT
Regional Trial Court
Branch 23
Davao City

MA’AM:

Greetings!
Please take notice that on March 12, 2020 at 8:30 o’clock in the
morning or upon the approval of the Honorable Court the instant Petition
shall be heard.

Thank you.

ATTY. PAULO JOSE S. VILLARIN

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