WHEREFORE, premises considered, it is prayed of this

Honorable Court, that the herein Motion be GRANTED and Accused

be RELEASED on his own recognizance pursuant to R.A. No. 10389
and other pertinent implementing rules and regulations.

Other reliefs just and equitable are likewise prayed for.

Cebu City. August, 2017.

Counsels for Accused:

ATTY. JOHN D. CROSS

ROLL OF ATTORNEYS NO. 34931
IBP NO. 616994; CEBU CITY; LIFETIME MEMBER
PTR No. 1234567; CEBU CITY; 1-9-17
MCLE Compliance No. V – 00244468; December 8, 2016
Pelaez Corner Sanciangko St.,
Cebu City, 6000 Cebu

Copy furnished by personal service:

ATTY. JON T. SNOW

Office of the City Prosecutor
D. Jakosalem Street, Cebu City, Cebu

NOTICE OF HEARING

ATTY. JON T. SNOW

Office of the City Prosecutor
D. Jakosalem Street,
Cebu City, Cebu

Sir:

Please take notice that a foregoing Motion for Release on Own

Recognizance in Criminal Case No. 12345 pending under the Branch 15
of the Municipal Trial Court in Cities (MTCC) of Cebu shall be
submitted for the consideration and approval of the Honorable Court
on Friday, August 18, 2017 at 9 AM or as soon as counsel and matter
may be heard.

ATTY. JOHN D. CROSS

Counsel for Accused
Pelaez Corner Sanciangko St.,
Cebu City, 6000 Cebu

Republic of the Philippines }

Cebu City } s.s.

AFFIDAVIT OF INDIGENCY

I, JUAN DE LA CRUZ, of legal age, single, Filipino citizen, and

presently residing at Cebu City, after having been duly sworn to in
accordance with law, do hereby depose and say:

1. That I am self-employed as a trisikad driver with no stable source

of livelihood or income;

2. That every month I earn, more or less, only TWO THOUSAND

PESOS (₱2,000.00);

3. That I do not own any sufficient personal and real properties;

4. That because of the abovementioned facts, I am incapacitated

either to post a cash bail or proffer any personal or real property
acceptable as sufficient sureties for a bail bond; and

5. That I am executing this Affidavit to entitle me to be released on

my own recognizance and for whatever legal purpose it may
serve.

IN WITNESS WHEREOF, I have hereunto set my hand this 8th

day of August 2017 at Cebu City, Philippines.
 JUAN DE LA CRUZ
Affiant

SUBSCRIBED AND SWORN to before me this 8th day of August 2017

in Cebu City, Philippines, and I have read and translated the foregoing
Affidavit in a dialect known and understood by the affiant.

Doc No. 81
Page No. 17 ATTY. JOHN D. CROSS
Book No. V NOTARIAL COMMISSION NO. 030-17
Series of 2017 NOTARY PUBLIC, CEBU CITY
UNTIL DECEMBER 31, 2018
IBP NO. 616994; CEBU CITY; LIFETIME MEMBER
Republic of the Philippines
PTR No. 1234567; CEBU CITY; 1-9-17
Province of CebuROLL OF ATTORNEYS NO. 34931
City of Cebu
City Social Welfare and Development Office

CERTIFICATE OF INDIGENCY

TO WHOM IT MAY CONCERN:

This is to certify that JUAN DE LA CRUZ, of legal age, son of Mr. and
Mrs. Pedro and Joanna de la Cruz, is a bona fide resident of Barangay
North Westeros, Cebu City, Cebu. The said person is of good moral
character and an active member of the community.

Juan de la Cruz has eight (8) siblings and belongs to a low-income

family with a combined annual net income of not exceeding forty-
thousand pesos (₱40,000.00), which is below the poverty line.

This certification is being issued upon the request of the above-named

person for whatever purposes it may serve him best.

Given this 28th day of July 2017 at Cebu City, Cebu.

AEGON TARGARYEN
Head of Office