Republic of the Philippines
NATIONAL CAPITAL JUDICIAL REGION
METROPOLITAN TRIAL COURT
Branch xxxxxxxxxxx
PEOPLE OF THE PHILIPPINES,
-versus- CRIM CASE NO.
xxxxxxxxxx
For: Violation of P.D. No.
1602
xxxxxxxxxxx,
x-----------------------------------------------------x
EX-PARTE MOTION TO ORDER
RELEASE OF CASH BOND
ACCUSED, Juan Dela Cruz, through and by himself,
and unto this Honorable Court, most respectfully states---
THAT:
1. During the last hearing held on August 26, 2020,
Juan Dela Cruz and his co-accused, assisted by PAO Counsel
xxxxxxxxxxxxx, pleaded guilty to the charge of violation of
P.D. 1602 after their arraignment;
2. Thereafter, the Hon. Court found all the accused
guilty beyond reasonable doubt of the offense charged (P.D.
1602) and sentenced them to pay a fine of xxxxxxxxxxxx
plus P10.00 cost each;
2. Due to inadvertence, the assisting PAO Counsel
failed to move for the release and/or return of the cash bond
posted by the undersigned accused for his provisional
liberty pending trial;
3. Accordingly, accused thru and by himself,
respectfully moves that a directive for the release of the
cash bond that was posted for his provisional liberty be
ordered by the Honorable Court;
*Photostat copies of the corresponding Official
Receipts for the Cash Bond posted by the said accused are
hereto attached as Annexes “1” & “1-A”, respectively;
PRAYER
WHEREFORE, premises considered, it is respectfully
prayed of this Honorable Court, that an Order be issued di-
recting the release of the cash bond posted by the afore-
named accused in the above-entitled case.
Other reliefs as are just and equitable in the premises
are likewise prayed for.
Pasay City, for Caloocan City, September 25, 2020.
RESPECTFULLY SUBMITTED.
JUAN DELA CRUZ
Accused/Movant
NOTICE
The Branch Clerk of Court
Metropolitan Trial Court
Branch 123
Caloocan City
Greetings:
The foregoing motion not being litigious, please submit
the same to the Honorable Court for consideration and ap-
proval immediately upon receipt hereof, sans further argu-
ments and appearance from the accused and assisting PAO
Counsel, Atty. Juana Penelope.
JUAN DELA CRUZ
Copy furnished:
xxxxxxxxxxxxxxxxxxxxxxxx (Personal)
Public Prosecutor
Office of the City Prosecutor
xxxxxxxxxxxxxxxxxxxxxxxxxxxx (Personal)
Public Defender
xxxxxxxxxxxxxxxxxxxxx
