Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch 60
Makati City

People of the Philippines,

Complainant
Criminal Case No. ______
For: Qualified Theft
-versus-

W, X, Y, and Z
Accused
x---------------------------------x

MOTION TO REDUCE BAIL

Come now all the accused, through counsel, unto this
Honorable Court, respectfully allege:

1. That, all the accused have been charged with Qualified

Theft and that the bail for their provisional liberty has been set
at P200,000.00;

2. That the accused come from indigent families of very limited

means, such that, it is impossible for them to pay the full
amount of their bond and are, therefore, constrained to
request for a reduction of the amount of bail;

3. That they would like to exercise their constitutional right to

post bail while this case is on trial;

1
4. As such, accused appeals to the mercy and compassion of
this Honorable Court and respectfully request that their bail
be reduced to P80,000.00, an amount, which, if granted,
would come from loan and the help of the all the accused’
family and friends.

PRAYER

WHEREFORE, premises aforementioned considered, all the

accused respectfully pray unto the Honorable Court that this
motion be taken cognizance and their bail be reduced to
P80,000.00 in consonance with their constitutional right to
post bail.

Other reliefs just and equitable are, likewise, prayed for.

Makati City, Philippines, August 22, 2019.

Counsel for all of the Accused

Roll No. 1234
MCLE Compliance No. VI-54321-19
PTR No. 54321, Makati City

Copy furnished (through personal service)

Assistant City Prosecutor

Office of the City Prosecutor
Makati City

THE BRANCH CLERK OF COURT

RTC – BRANCH 60
2
Makati City

Greetings:

Please set for hearing the aforementioned on August 25,

2019 at 8:00 o’clock in the morning or on any other date
convenient to the Honorable Court.

Counsel for the accused