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Republic of the Philippines

REGIONAL TRIAL COURT


Fourth Judicial Region
Branch 17, Cavite City

PEOPLE OF THE
PHILIPPINES,
Plaintiff,
CRIM. CASE
NO.481-18
For: VIOL. OF R.A
7610 SEC. 10
-versus- (a) OTHER
ACTS OF
ABUSE
FELIPE R. COSTUNA, JR., UNDER ART.
Accused. VI
x----------------------------------x

MOTION TO REDUCE BAIL


Accused, through counsel, by way of a special appearance
solely for this purpose, respectfully alleges:

1. That the accused has been charged with Violation of


R.A. 7610 Sec. 10 (a) Other Acts of Abuse under Art. VI
and that the bail for his provisional release has been set
at EIGHTY THOUSAND PESOS (Php 80,000.00);

2. That the accused is just an employee in the private


sector with very limited means such that it is impossible
for him to pay the full amount of his bond and is
therefore constrained to request for a reduction of the
amount of bail;

3. That it would be advantageous to everyone if he be


given temporary liberty thereby allowing him to
continue with his gainful employment and as head of the
family;

4. As such, accused appeals to the mercy and compassion


of this Honorable Court and respectfully requests that
his bail be reduced to FORTY THOUSAND PESOS
(Php 40,000.00) or a lesser amount depending on
the discretion of the Honorable Court.

5. That this motion for reduction of bail is being filed


without prejudice to any other remedy which may be

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available to the accused and that the accused expressly
reserves the right to question the legality of the issuance
of the search warrant or his arrest if the circumstances
would so warrant.

PRAYER

WHEREFORE, based on the premises presented, it is


most respectfully prays that his bail be reduced to FORTY
THOUSAND PESOS (Php 40,000.00) or a lesser amount
depending on the discretion of the Honorable Court.

Other relief just and equitable are likewise prayed for.

By:

NEMUEL RESURRECCION CAMARSE


Counsel for the Detained

Roll No. 69395


IBP No. 003320; 05.24.2018
PTR No. CVT 0369759; 05.24.2018
MCLE Compliance No.: New Lawyer
Mobile : 09178036938
Email: coycamarse1008@gmail.com

NOTICE OF HEARING

To: Branch Clerk of Court


RTC Br. 17, City of Cavite

Warmest greetings! Please take note that the foregoing


Motion shall be submitted for the consideration and approval
of the Honorable Court on the day submitted.

NEMUEL RESURRECCION CAMARSE

Copy furnished via registered mail with return card:

City Prosecutors Office

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Cavite City

Lee Baron Reg y Nepomuceno


Plaintiff

Explanation

Copy of this Motion was served to the abovementioned


concerned party via mail with return card due to lack of
manpower complement.

NEMUEL RESURRECCION CAMARSE

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