REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH 172, VALENZUELA CITY

PEOPLE OF THE PHILIPPINES,

-versus- Criminal Case No. 1021-V-18

For: Violation of Section 5 (i)
R.A. 9262

MICHAEL MARTINEZ y BABOL,

Accused.
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APPLICATION/MOTION FOR BAIL

ACCUSED MICHAEL MARTINEZ y BABOL, assisted by and
through the undersigned counsel, unto this Honorable Court, hereby
respectfully applies for bail and in support thereof respectfully states:
That –

1. On 6 July 2018, the Honorable Court issued an Order for

the arrest of the above-named accused in connection with the above-
entitled case.

2. The amount of bail that was recommended by the

Honorable Court was PESOS: TWENTY FOUR THOUSAND
(Php24,000.00).

3. Accused hereby respectfully manifests his intention to

apply for bail. Further, accused manifests that he will post a cash
bond to secure his provisional liberty during the pendency of the
above-entitled cases.

4. This motion is not in any way intended to cause delay in

the prompt disposition of the instant case or for any other purpose
other than as stated above.

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed of this Honorable Court to give DUE COURSE to the instant
Application for bail bond and that the instant Motion be GRANTED.
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 OTHER RELIEFS, just and equitable under the premises, are
likewise most respectfully prayed for.

RESPECTFULLY SUBMITTED.

Cainta for Valenzuela City, 4 January 2019.

RICARDO T. MARTINEZ, JR.

Counsel for the Accused
Greenwoods Executive Village
Lot 8, Block 26, Chestnut St.
Cainta, Rizal
PTR No. 6615378;1/4/18; Makati City
IBP Life Member Roll No. 014263
Roll of Attorneys No. 52393
MCLE Compliance No. V-0012346;12/8/15
Tel No. (+632) 759-9888 local 1266
Fax No. (+632) 895-1028

Conforme:

_______________________
MICHAEL B. MARTINEZ
Accused

NOTICE OF HEARING

THE HONORABLE BRANCH CLERK OF COURT

Regional Trial Court
Branch 172, Valenzuela City

THE HONORABLE PROSECUTOR

Regional Trial Court,
Branch 172, Valenzuela City

Greetings:

Please take notice that the undersigned counsel shall submit

the foregoing motion for the due resolution and approval of the
Honorable Court immediately upon receipt hereof by virtue of the
urgency of the matter prayed therein.

RICARDO T. MARTINEZ, JR.

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Copy furnished by personal service:

THE HONORABLE PROSECUTOR

Regional Trial Court
Branch 172, Valenzuela City