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Motion to Reduce Bail

The document is a motion filed by Jick Sanz Gutierrez, the accused in a perjury case, requesting a reduction of bail from P18,000.00 to P5,000.00 due to financial constraints as he is an on-call multicab driver. The motion argues that the current bail amount is excessive and that the accused poses no flight risk, being a good community member with no prior convictions. The motion is submitted for consideration by the court on August 15, 2024.

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Hasmin Perez
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2 views2 pages

Motion to Reduce Bail

The document is a motion filed by Jick Sanz Gutierrez, the accused in a perjury case, requesting a reduction of bail from P18,000.00 to P5,000.00 due to financial constraints as he is an on-call multicab driver. The motion argues that the current bail amount is excessive and that the accused poses no flight risk, being a good community member with no prior convictions. The motion is submitted for consideration by the court on August 15, 2024.

Uploaded by

Hasmin Perez
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

COURT
Fourth Judicial Region
Branch 123
Imus City

THE PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO.29046-24,


Complainant, 29047-24
FOR: PERJURY
-versus-

Jick Sanz Gutierrez


Accused.
X---------------------------X

MOTION TO REDUCE BAIL

UNTO THIS HONORABLE COURT, Accused, through representative, most


respectfully aver:

1. That Accused is presently detained at Police Station,Imus 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 P18,000.00;

3. That the recommended bail for the offense of Perjury is P18,000.00,


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 on-call multicab


driver;

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 5,000, which


amount the accused can raise because he is a bread winner to his
family;

7. That accused is a good member of the community, and a resident of


Imus City, Cavite 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 5,000.00 for
his provisional liberty during the pendency of this case.

Imus City, Cavite, Philippines, August 15, 2024.

By:

MARITES C. LOBRIANO
Representative for the Accused

NOTICE OF HEARING

THE CITY PROSECUTOR


City Prosecution Office of Imus, Cavite
________________________
________________________

THE CLERK OF COURT


REGIONAL TRIAL COURT
BRANCH 123
CITY OF IMUS, CAVITE

Greetings:

Please submit the foregoing Motion for the consideration and approval of this Honorable Office on
August 15, 2024 at __________o’clock in the morning or as soon as this may be heard.

ATTY. ______________________

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