Republic of the Philippines COURT
Judicial Region Branch ___ Davao City THE PEOPLE OF THE PHILIPPINES, Complainant, -versus- NAME OF ACCUSED Accused. X - - - - - - - - - - - - - - - - - - - - - - - - - - - X CRIMINAL CASE NO.________________ FOR: ESTAFA
MOTION TO REDUCE BAIL
UNTO THIS HONORABLE COURT, Accused, through counsel, most respectfully aver: 1.
That Accused is presently detained at Police Station, ________ 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 Davao City, and the probability of flight is nil;