REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

11th JUDICIAL REGION
BRANCH 15
DAVAO CITY

PEOPLE OF THE PHILIPPINES,

Petitioner
Criminal Case No. 96767
- versus - For: Murder

GIL-GALAD,
Respondent.
x ------------------------------------------ x

MOTION TO REDUCE BAIL

Accused GIL-GALAD, through counsel, by way of a special

appearance solely for this purpose, respectfully alleges that:

1.The accused has been charged with Murder and that the bail for his
provisional release has been set at P500,000;

2. The accused is a poor fellow of very limited means 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;

3. It would be advantageous to everyone if he be given temporary liberty

thereby allowing him to continue with his gainful employment and as head
of the family with two dependents;

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

Court and respectfully requests that his bail be reduced to P100,000

5. This motion for reduction of bail is being filed without prejudice to any
other remedy which may be available to the accused and that the accused
expressly reserves the right to question the legality of the issuance of the
search warrant or his warrantless arrest if the circumstances would so
warrant.
 PRAYER

WHEREFORE, accused respectfully prays that his bail be reduced to

P100,000.

Other relief just and equitable are likewise prayed for.

Davao City, Philippines, March 15, 2020.

(Sgd.) Gil-Galad
Respondent

ASSISTED BY:
(SGD.)
ATTY. AVEN SINA B. CAUBANG
COUNSEL FOR RESPONDENT
ROLL OF ATTY. NO 718308
IBP NO. 187308;
PTR NO. 1806083A; 1/8/2020
MCLE NO. 524162

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

Regional Trial Court
11th Judicial Region
Davao City, Branch 15

THE HONORABLE ASSISTANT CITY PROSECUTOR

Office of the City Prosecutor
Hall of Justice, Davao City

Greetings:

Please take notice that the foregoing Motion will be submitted for the
Court’s consideration and resolution on March 20, 2020 at 8:30 a.m. or as
soon thereafter as matter and counsel may be heard.

(Sgd.) Atty. Aven Sina B. Caubang

Counsel for Respondent
COPY FURNISHED:

THE BRANCH CLERK OF COURT

Regional Trial Court
11th Judicial Region
Davao City, Branch 15

THE HONORABLE ASSISTANT CITY PROSECUTOR

Office of the City Prosecutor
Hall of Justice, Davao City