Republic of the Philippines

REGIONAL TRIAL COURT

___th Judicial Region
Branch __, ____ City

PEOPLE OF THE CRIMINAL CASE NO.

PHILIPPINES,
NPS DOCKET NO.
- versus -
FOR: VIOLATION OF
SECTION 11 in RELATION
JUAN DELA CRUZ, TO SECTION 25 of RA 9165
as Amended by RA No.
Accused. 10640
x----------------------
--- -x

MOTION FOR RECONSIDERATION

COMES NOW, the undersigned counsel, and unto this

Honorable Court, most respectfully states that:

1. On March 19, 1998, the Accused filed its Petition for

Bail with Motion to Reduce Bail. A copy of which is hereto
attached and marked as Annex “1”;

2. Upon inquiry over the phone to RTC Branch 9, the staff

of the undersigned counsel was informed that there would be no
hearing for that week and that hearings will start this week or on
March 10, 1998;

3. Thus, the undersigned respectfully requested in the

Notice of Hearing that the Motion be heard on March 10, 1998 or
any date thereafter subject to the availability of the Honorable
Court’s calendar;

4. In the afternoon of March 22, 1998 (Friday), the

undersigned counsel inquired from this Honorable Court to
confirm the schedule of the hearing. Unfortunately, the
undersigned counsel was informed that the aforementioned
Petition for Bail with Motion to Reduce Bail already was set for
hearing that day but the undersigned counsel failed to appear;

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 5. The undersigned counsel was not able to attend the
aforementioned hearing because neither the undersigned counsel
nor any of his staff receive any communication that the same was
set for hearing that day contrary to the earlier information he
received that court hearings will resume this week. The
undersigned counsel has no intention whatsoever to disregard the
scheduled hearing and waste the precious time of this Honorable
Court;

6. Thus, in view of the foregoing, the undersigned

respectfully beseeches the compassion and understanding of the
Honorable Court to reconsider the denial of the Motion to Reduce
Bail on humanitarian considerations in order for the Accused to
enjoy her right to post bail despite her family’s dire financial
constraints and spare her and her family from the tormenting
anxiety on the thought that the Accused may be infected with
Spanish Flu while under detention.

PRAYER

WHEREFORE, premises considered, it is most respectfully

prayed of this Honorable Court to reconsider the denial of the
subject Petition for Bail with Motion to Reduce Bail filed by
Accused and grant the Accused’s prayer for the reduction of the
recommended bail.

Other reliefs just and equitable are likewise prayed for.

Davao City, Philippines, March 26, 1998.

Assisted by:

LAWYER

NOTICE OF HEARING

THE CLERK OF COURT

BRANCH __, RTC of _____ City

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THE CITY PROSECUTOR
City Prosecution Office
Hall of Justice, _____ City

Greetings:

Please submit the foregoing Motion for Reconsideration for

the consideration and approval of this Honorable Court and/or set
the same for hearing on May 29, 2020 at 2:00 o’clock in the
afternoon or as soon as this may be heard subject to the
availability of this Honorable Court’s calendar.

LAWYE
R

Copy furnished:

City Prosecution Office Received by:

_________________________
______ City Date:
______________________________

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