REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Manila

PEOPLE OF THE PHILIPPINES,

Plaintiff,
- versus- CRIMINAL CASES Nos. 13-296691
13-296692

GERARDO T. TANATE,
Accused.
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URGENT MOTION TO REDUCE BAIL BOND

ACCUSED, assisted by the undersigned counsel, unto this Honorable

Court, most respectfully moves for the reduction of his bail bond, and respectfully
states:

1. That in the two (2) Informations filed in the above-entitled cases,

the total recommended bail bond for accused’s provisional liberty is Sixty Six
Thousand (Php 66,000.oo) Pesos;

2. That due to unavailable financial resources, accused could not

produce and raise such substantial bail bond amount, and thus appeals to the
kindness of this Honorable Court for the reduction of his bail bond in the total
amount of Thirty Three Thousand (Php 33,000.oo) for the above two cases;

3. That accused filed this motion in view of the urgent and pressing
need.

WHEREFORE, premises considered, it is most respectfully moved that

Accused be allowed to post his bail bond for the above two (2) cases at a
reduced CASH BOND in the total amount of THIRTY THREE THOUSAND (Php
33,000.oo) Pesos. Other reliefs just and equitable in the premises are likewise
sought.

Mandaluyong City for Manila, April 29, 2013.

Atty. ROGER ALIM RODRIGUEZ

Counsel for Accused
Unit 319 San Rafael Condominium
San Rafael corner San Ignacio Streets
1550 Mandaluyong City, Philippines
P.T.R. No. 8439481 * Pasig City * January 11, 2013
I.B.P No. 882584 * Pasig City * January 10, 2013
MCLE No. III 14549 * Pasig City * April 26, 2010
Roll No. 47673
 NOTICE OF HEARING

The Clerk of Court

Regional Trial Court
Manila

The City Prosecutor’s Office

Manila

Greetings:

Please be informed that undersigned counsel hereby request

to submit the foregoing motion for the consideration and approval
of the Honorable Court immediately upon its receipt by the
Honorable Clerk of Court.

ROGER ALIM RODRIGUEZ

EXPLANATION

This is to certify that a copy of the foregoing motion was

furnished personally to the Office of the City Prosecutor Manila by
personal service.

ROGER ALIM RODRIGUEZ

COPY FURNISHED:

Office of the City Prosecutor

Manila

NO OBJECTION:

Office of the City Prosecutor

Manila