Republic of the Philippines

REGIONAL TRIAL COURT

___th Judicial Region
Branch __, ____ City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO.

NPS DOCKET NO.

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

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;

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 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

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.

LAWYER

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Copy furnished:

City Prosecution Office Received by: _________________________

______ City Date: ______________________________

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