Republic of the Philippines

Regional Trial Court

National Capital Region
Branch 100, Quezon City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

- versus - Crim. Case No. Q-10-165152

For: Frustrated Homicide

PSSUPT. NAPOLEON CASTRO,

Accused.
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URGENT EX-PARTE MOTION TO REDUCE BAIL

Accused, by and through the undersigned counsel unto this Honorable

Court most respectfully avers, that:

1. On January 22, 2010, Information was filed against herein accused for
violation of Frustrated Homicide.

2. The Honorable Public Prosecutor recommended a bail for his provisional

liberty in the amount of Twenty-Four Thousand Pesos (Php 24, 000.00).

3. Accused, due to financial constraints, foresees the impossibility of raising

the required amount of bail for his provisional liberty.

4. Accused most respectfully begs the kind indulgence, mercy and

understanding of this Honorable Court to reduce the recommended bail from
Twenty-Four Thousand Pesos (Php 24,000.00) to Twelve Thousand Pesos (Php
12,000.00).

5. Accused undertakes to be present in all succeeding hearings whenever his

presence is required by this Honorable Court or by the Rules of Court after he is
released on bail.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court that an Order be issued:

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 a. REDUCING the bail bond of the Accused from Twenty-Four
Thousand Pesos (Php 24,000.00) to Twelve Thousand Pesos (Php
12,000.00); and

b. LIFTING/RECALLING the warrant of arrest issued against the

Accused after he had posted his bond for his temporary liberty.

Such other reliefs and remedies as are just and equitable under the
foregoing premises are like wise equally prayed for.

August 3, 2010. Quezon City .

G.P. ANGELES AND ASSOCIATES LAW OFFICES

Counsel for the Accused
Units 308-309 West City Plaza Bldg.
66 West Avenue, Quezon City 1100
Tel. Nos. 412-4465; 376-2224(Telefax)

by:

GALELEO P. ANGELES
IBP Lifetime No. 05517/QC
PTR NO. 3176655/1-04-10/ QC
Roll No. 46286
MCLE Compliance No. III-0012946

ARISTOTLE T. POBLETE
IBP NO.786969/ 1-19-10 / Q. C.
PTR No. 3176656/1-04-10/ Q. C.
MCLE Compliance No. II-0007294
Roll No. 52162

NOTICE OF HEARING

To the Branch Clerk of Court

Regional Trial Court
Branch 100, Quezon City

Hon. Public Prosecutor

RTC Br. 100, Quezon City

GREETINGS:

In view of the urgent nature and for the reason that the matter rests
exclusively to the sound discretion of the Honorable Court, kindly submit the
foregoing motion for its consideration and approval immediately upon receipt
hereof.

ARISTOTLE T. POBLETE

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