Republic of the Philippines

National Capital Judicial Region

METROPOLITAN TRIAL COURT
Branch
City of XXX

PEOPLE OF THE PHILIPPINES,

Plaintiff/s

Criminal Case No. XXXX

FOR:
- versus - THEFT

RUBEN,
Accused.
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URGENT EX-PARTE MOTION TO REDUCE BAIL

COMES NOW, ACCUSED/MOVANT, RUBEN, assisted by

the Public Attorney’s Office, and unto this Honorable Court, most
respectfully submits this Urgent Ex-Parte Motion to Reduce Bail, and
hereby avers:

1. Accused/Movant is charged before this Honorable Court

for the above-mentioned criminal case for which the recommended
bail for his temporary liberty is Ten Thousand Pesos (Php10,000.00);

2. He is presently detained at Las Piñas City Jail. Hence, he

would like to post bail in the reduced amount of Five Thousand
Pesos (Php5,000.00) for his provisional liberty;

3. The accused is in dire financial need and has no means to

pay the whole amount of bail, thus, he cannot post the recommended
bond for his provisional liberty, and will rely on his family and
friends for financial assistance. A copy of his Certificate of Indigency
Criminal Case No. XXXX
PP vs. Ruben
URGENT EX-PARTE MOTION TO REDUCE BAIL
page 2 of 3
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to prove that the accused belongs to the indigent family and

unemployed is hereto attached and marked as ANNEX “1”;

4. Under Section 4 of A.M. No. 12-11-21, if the accused does

not have the financial ability to post the amount of bail that the court
initially fixed, he may move for its reduction, submitting for that
purpose such documents or affidavits as may warrant the reduction
he seeks;

4.1 The Supreme Court Committee for the

Decongestion of Provincial City, and Municipal Jails has
recommended for the adoption of guidelines for
decongesting holding jails by enforcing the rights of
accused persons to bail and to speedy trial;

5. Considering that the accused is still presumed innocent

until proven guilty, as guaranteed by our Constitution2 and
embodied in the Rules of Court3, we seek the indulgence of this
Honorable Court to allow the accused to post bond in a reduced
amount in order for him to enjoy his temporary liberty outside the
congested Las Piñas City Jail.

PRAYER

WHEREFORE, premises considered and in the interest of

substantial justice, accused pray that he be allowed to post cash bond
in the amount of Five Thousand Pesos (Php5,000.00).

Other relief and remedies as may be deemed just and equitable

under the premises are likewise prayed for.

RESPECTFULLY SUBMITTED.

1 Guidelines For Decongesting Holding Jails By Enforcing The Rights Of Accused Persons To Bail
And To Speedy Trial
2 Section 14(2), Article III (Bill of Rights) of the 1987 Philippine Constitution

3 Section 2, Rule 133 of the Rules of Court

Criminal Case No. XXXX
PP vs. Ruben
URGENT EX-PARTE MOTION TO REDUCE BAIL
page 3 of 3
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August 16, Las Piñas City, Philippines.

DEPARTMENT OF JUSTICE
PUBLIC ATTORNEY’S OFFICE
2nd Floor, Hall of Justice
Las Piñas City Hall Compound
Las Piñas City

By:

PUBLIC ATTORNEY I
Roll No.: XXXX dated 25 May 2017
IBP Lifetime Membership No.XXXX dated 5
January 2018
MCLE Compliance No.: Exempt under Bar
Matter No. 850, as amended.

Copy furnished (through personal service):

HON. PAUL
Assistant City Public Prosecutor
Office of the City Prosecutor
Las Piñas City

THE BRANCH CLERK OF COURT

MTCC – Branch

Greetings:

Please include the hearing of the Urgent Ex-Parte Motion to

Reduce Bail in the calendar of cases of the Honorable Court on
Friday, August 17, 2018 at 1:30 in the afternoon.

ATTY. MARI