Republic of the Philippines

REGIONAL TRIAL COURT

5th Judicial Region
Branch ___
Naga City

PEOPLE OF THE PHILIPPINES, Crim Case No. 2017-0868

Complainant
For: Violation of |RA 9262
(non-support)
-versus –

MARK JOSEPH B. LANSANGAN

Accused
x-------------------------------------------x

VERY URGENT MOTION TO REDUCE BAIL

Accused MARK JOSEPH B. LANSANGAN, by himself, unto this

Honorable Court, most respectfully alleges that:

1. Above-named accused is charged with Violation of R.A. 9262 (non-

support). The bail for said offense is set at Php 72,000.00;

2. Undersigned accused is a poor and indigent fellow of very limited

means off income such that it is impossible for him to pay the full
amount of his bond and is therefore constrained to request for a
reduction of the amount of bail; and to prove such effect, attached
hereto are the Certificate of Indigency (Annex “A”) issued by the
Punong Barangay of Sto. Niño, Minalabac, Camarines Sur,

3. It would be advantageous to everyone and in consonance with his

constitutional rights to bail if above-named accused be given
temporary liberty thereby allowing him to continue to care for his
dependent children;

4. As such, accused appeals to the mercy and compassion of this

Honorable Court and respectfully requests that his bail be reduced to
from Php 72,000.00 to Php 35, 000.00 in the interest of justice;

WHEREFORE, it is respectfully prayed of this Honorable Court that

his bail for be reduced to Php 35,000.00 if only for accused to avail of his
constitutional right to bail.

Other relief just and equitable are likewise prayed for.

Naga City, Camarines Sur, 28 June 2019

MARK JOSEPH B. LANSANGAN

Accused
THE BRANCH CLERK OF COURT
Regional Trial Court, Branch __
Naga City

Greetings!

Please submit the foregoing motion to the Honorable Court on 28 June

2019 at 8:30 in the morning or soon as the matter could be heard at the
discretion of the Honorable Court for its favorable consideration and
approval, sans appearance or argument.

MARK JOSEPH B. LANSANGAN

Copy furnished:

Office of the City Prosecutor

Naga City