Republic of the Philippines

____________________________
_______________ Judicial Region
____________________

PEOPLE OF THE PHILIPPINES,

Plaintiff,

CRIMINAL CASE NO. ______

-versus-
for
Acts of Lasciviousness

______________________
Accused.
x- - - - - - - - - - - - - - - - - - - - - - x

MOTION TO REDUCE BAIL

ACCUSED, ____________________, through the Public Attorney’s
Office by the undersigned counsel and unto this Honorable Court
with utmost respect states that:

1. Accused is presently unemployed who merely depends

on his wife’s very minimum earnings. With this, accused is a
pauper litigant and indigent as evidenced by his Affidavit of
Indigency executed before __________________. Appended hereto and
marked “herein as Annex “A”.

2. Accused is presently under the custody of PNP Ilagan,

Isabela;

3. Accused earnestly asks for the reduction of his bail

recommended in the amount of Thirty Six Thousand pesos (P
36,000.00) in the above-mentioned Criminal Case to Eighteen
Thousand pesos (P 18,000.00) considering that he merely rely on
the earning of his wife and has no other source of income as of the
moment due to the present pandemic.

4. This is only the first time that the accused was

charged of this crime and not a flight risk because he want to prove
that the criminal case filed against him is unfounded and therefore
innocent thereof;

5. Accordingly, accused earnestly requests that his bail

recommended in the amount of Thirty Six Thousand pesos (P

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36,000.00) in Criminal Case No. 20-73 be reduced to Eighteen
Thousand pesos (P 18,000.00) in order for him to enjoy his
provisional liberty; and

6. That in the event the Honorable Court will grant this

Motion to Reduce Bail, accused undertake to appear before this
Honorable Court whenever he is required to do so.

PRAYER

WHEREFORE, premises considered, it is most

respectfully prayed of this Honorable Court that an order be issued
granting this Motion to Reduce Bail from Thirty Six Thousand pesos
(P36,000.00) be reduced to Eighteen Thousand pesos (P 18,000.00)
in order for accused to enjoy his provisional liberty.

Other reliefs just and equitable under the premises are

likewise prayed of.

City of Ilagan, Isabela, 03 August 2020.

by:

____________________________
Attorney
Roll No. _______________

REQUESTS AND NOTICE OF HEARING

_________________________
CLERK OF COURT
_______________________
________________________

Please include in the courts calendar of cases as soon as

counsel may be heard, the foregoing Motion to Reduce Bail for the
kind consideration and resolution of the Honorable Court.

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 _________________________________
Attorney

__________________
Prosecutor I
__________________
__________________

G R E E T I N G S!

Please be informed that as soon as counsel may be heard, the

undersigned counsel will submit to the Honorable Court the
foregoing Motion to Reduce Bail for its kind consideration and
resolution.

***************
Attorney

Copy furnished:

_______________
Prosecutor II
_______________
_______________

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