REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SIXTH JUDICIAL REGION
BAGO CITY
Branch 62

PEOPLE OF THE PHILIPPINES,

-versus- Criminal Case No. 4161

For: Frustrated Murder

JONAS LUHAN, et. al.,

Accused.
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MOTION
TO RELEASE CASH BOND
Accused, Jonas Luhan, by counsel, respectfully states:

1. On December 04, 2019, the law office of the undersigned counsel

received the Order of this Honorable Court granting the Demurrer of Evidence filed
by Jonas Luhan. Incorporated in the aforesaid Order, this Court ordered the dismissal
of the case filed against Jonas Luhan.

2. In lieu thereof, Accused Jonas Luhan, after his voluntary surrender,

posted a cash bond of P100,000.00, through Jose D. Luhan Jr., for his provisional
liberty on July 10, 2018.

3. Therefore, Accused Jonas Luhan, by counsel, moved for the release of

his cash bond.

4. This Motion is intended solely for the foregoing reason.

RELIEF

WHEREFORE, premises considered, Accused Jonas Luhan respectfully

prayed for the release of his cash bond amounting to P100,000.00.

Other equitable reliefs are likewise prayed for.

Bacolod City, December 16, 2019.

 CATACUTAN & SINCO
LAW OFFICES
Door No. 4, 2nd Floor,
Esteban – Magdalena Bldg.,
Hernaez Street, Brgy 38, Bacolod City
Negros Occidental, 6100
Office Landline No.: 034-447-5365

By:

GABRIEL P. SINCO
IBP LRN No. 072264; 01-25-19
PTR No. 7554400; 01-23-19
Negros Occidental Chapter
Attorney’s Roll No. 67606
MCLE Compliance No. VI-008750; 04-14-22

Copy Furnished to:

Hon. Maria Christy E. Uriarte

Deputy City Prosecutor
Bago City