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    Motion To Reduce Bail

    Uploaded by

    Mitzi Syjongtian
    This document is a motion to reduce bail filed on behalf of the accused Bryan M. Emolaga in Criminal Case No. R-QZN-19-11093 for the offense of Estafa. The motion requests that the court reduce the bail amount set by the Office of the City Prosecutor of P20,000 to P10,000, as the recommended bail for Estafa is P6,000 according to the Department of Justice guidelines. It argues that the accused has limited means as a minimum wage employee, is not a flight risk as a resident of Quezon City with no prior convictions, and will be present for court hearings. The motion prays that the court allow the accused to post bail in

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    Motion To Reduce Bail

    Uploaded by

    Mitzi Syjongtian
    89 views2 pages
    This document is a motion to reduce bail filed on behalf of the accused Bryan M. Emolaga in Criminal Case No. R-QZN-19-11093 for the offense of Estafa. The motion requests that the court reduce the bail amount set by the Office of the City Prosecutor of P20,000 to P10,000, as the recommended bail for Estafa is P6,000 according to the Department of Justice guidelines. It argues that the accused has limited means as a minimum wage employee, is not a flight risk as a resident of Quezon City with no prior convictions, and will be present for court hearings. The motion prays that the court allow the accused to post bail in

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    This document is a motion to reduce bail filed on behalf of the accused Bryan M. Emolaga in Criminal Case No. R-QZN-19-11093 for the offense of Estafa. The motion requests that the court reduce the bail amount set by the Office of the City Prosecutor of P20,000 to P10,000, as the recommended bail for Estafa is P6,000 according to the Department of Justice guidelines. It argues that the accused has limited means as a minimum wage employee, is not a flight risk as a resident of Quezon City with no prior convictions, and will be present for court hearings. The motion prays that the court allow the accused to post bail in

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    89 views2 pages

    Motion To Reduce Bail

    Uploaded by

    Mitzi Syjongtian
    This document is a motion to reduce bail filed on behalf of the accused Bryan M. Emolaga in Criminal Case No. R-QZN-19-11093 for the offense of Estafa. The motion requests that the court reduce the bail amount set by the Office of the City Prosecutor of P20,000 to P10,000, as the recommended bail for Estafa is P6,000 according to the Department of Justice guidelines. It argues that the accused has limited means as a minimum wage employee, is not a flight risk as a resident of Quezon City with no prior convictions, and will be present for court hearings. The motion prays that the court allow the accused to post bail in

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 2

    Republic of the Philippines

    REGIONAL TRIAL COURT


    National Capital Judicial Region
    Quezon City
    Branch 9

    THE PEOPLE OF THE CRIMINAL CASE NO. R-


    PHILIPPINES, QZN-19-11093
    Complainant, FOR: ESTAFA

    -versus-

    BRYAN M. EMOLAGA
    Accused.
    X-----------------X

    MOTION TO REDUCE BAIL

    UNTO THIS HONORABLE COURT, Accused, through


    counsel, most respectfully aver:

    1. That Accused is presently detained at Police Station,


    10 City, pending the hearing of this case, and that
    this case has been raffled to this sala;

    2. That the Resolution of the Honorable Office of the


    City Prosecutor has fixed the bail of the accused at
    P20,000.00;

    3. That the recommended bail for the offense of Estafa


    is P6,000.00, in accordance with the 2000 Bail Bond
    Guide of the Department of Justice National
    Prosecution Service;

    4. That accused is not affluent in life, being a mere


    employee with minimum wage;

    5. That the bail recommended is tantamount to the


    denial of bail. Where the right to bail exists, it should
    not be rendered nugatory by requiring a sum that is
    so excessive.
    6. That accused is asking for the reduction of bail to P
    10,000, which amount the accused can raise;

    7. That accused is a good member of the community,


    and a resident of Quezon City, and the probability of
    flight is nil;

    8. That accused has not been previously convicted of


    any crime and have no pending case in any judicial
    or quasi-judicial body in the Philippines.

    9. That accused will undertake to be present when this


    case is called in Court.

    PRAYER

    WHEREFORE, premises considered, it is most respectfully


    prayed that the Honorable Court will allow accused to post bail
    in the amount of P 10,000.00 for his provisional liberty during
    the pendency of this case.

    Quezon City, Philippines. October 17, 2019.

    By:

    MITZI LOVE C. SYJONGTIAN


    (Counsel of the Accused)
    Roll of Attorney No. 123456 April 11, 2017
    PTR OR No. 987654 5-06-15
    IBP OR No. 123456 4-27-15 Manila Chapter
    MCLE COMPLIANCE No. Exempt-New Passer
    Email add: [email protected]

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