Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

First Judicial Region
BRANCH 2
Baguio City

THE PEOPLE OF THE

PHILIPPINES,
Plaintiff, CRIM. CASE No. 136105

For:
- versus -
VIOLATION of SECTION
6 of RA No. 8485
JOEFFREY (JOE) PASOS,
Accused.
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MOTION to RELEASE BAIL

COMES NOW, the accused, through the

undersigned counsel, unto this Honorable Court, and
most respectfully states that:

1) On 26 April 2018, the accused, through the

undersigned counsel, received a copy of the Order of
the Honorable Court dated 20 April 2018, granting
the Demurrer to Evidence filed by herein accused,
thereby ordering the dismissal of the instant case
for insufficiency of evidence;

2) During the course of trial, the accused obtained

provisional liberty when he posted his bail bond in
the amount of TWO THOUSAND PESOS
(Php2,000.00), as evidenced by Official Receipt No.
4019501, attached to the records;

3) In view of the dismissal of the instant case, it is

most respectfully prayed of the Honorable Court to
release the cash bond posted to the payor, Joeffry
(Joe) Pasos, or his duly authorized representative.

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 PRAYER

WHEREFORE, premises considered, it is most

respectfully prayed of this Honorable Court to allow the
accused to withdraw the cash bond he posted for his
provisional liberty.

Other reliefs, just and equitable, are likewise prayed

for.

This 2nd day of May 2018, in the City of Baguio,

Philippines.

A B S LAW OFFICES
Suite 305, Laperal Building
Session Road, Baguio City
Tel. No. (074) 442 8243

By:

PATRICIA MARIE FRANCES D. CASTRO

PTR No. 3398888/12.11.2017/Baguio City
IBP Lifetime No. 012653/04.04.2014/Baguio City
MCLE Compliance No. V – 0002740
Roll No. 63622

The BRANCH CLERK of COURT

MTCC – Branch 2
Justice Hall, Baguio City

OFFICE of the CITY PROSECUTOR

Justice Hall, Baguio City

Please take notice that undersigned counsel will

submit the foregoing motion for the approval of the
Honorable Court sans further arguments and sans
appearance. Thank you.

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 PATRICIA MARIE FRANCES D. CASTRO

Copy Furnished:

OFFICE OF THE CITY PROSECUTOR

Justice Hall, Baguio City

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