Republic of the Philippines

MUNICIPAL TRIAL COURT IN CITIES

Ninth Judicial Region
BRANCH 02
Pagadian City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. ________________

Plaintiff,

versus FOR: _________________________

__________________________
Accused.
x------------------------------------------------------x

NOTICE OF ENTRY OF APPEARANCE WITH

URGENT MOTION FOR RECONSIDERATION AND
MOTION TO LIFT WARRANT OF ARREST
COMES NOW, accused-movant______________________, before this Honorable Court, most
respectfully avers and moves:

1. The undersigned counsel respectfully enters his appearance as counsel for the accused;

2. On _____________________, the undersigned received a copy of the order forfeiting the bail
bond posted by the accused for his temporary liberty and thereafter issued a warrant of arrest
due to the non-appearance of the accused in a hearing conducted via videoconference on
_____________________________;

3. Although the accused was notifiedof the said scheduled hearing as appearing in the Order
dated _______________________; however, he is a resident of Guadalupe, Cebu City and it
is a public knowledge that Cebu City was placed under Enhanced Community Quarantine
(ECQ) from June 16 to 30, 2020;

4. With the implementation of the ECQ within Cebu City, the accused cannot at his own will travel
outside of his residence for if he did, he might be arrested again for violation of existing laws;

5. The undersigned counsel who assisted the accused in the posting of his bail but who is just
formally hired as his counsel was also not notified of the aforesaid schedule of hearing via
videoconferencing but surprisingly, he received via e-mail a copy of the court’s order dated
July 16, 2020;

6. With all due respect and humility, the accused most respectfully appeals to the mercy and
compassion of this Honorable Courtto reconsider its Order dated June 16, 2020by lifting the
warrant of arrest it issued against the accused in order for him not to post a bond for the
second timegiven the unprecedentedill effects of the CoViD-19 pandemic among all walks of
life.

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of this Honorable Court that
thecourt order dated June 16, 2020BE RECONSIDERED AND SET ASIDEwhereby the Warrant of Arrest
issued against the accused BE LIFTED; the corresponding bail fixed anew at Six Thousand Pesos (P6,
000.00) for each case forhis temporary liberty BE CANCELLED; thus, allowing him to use the previous bail
bond he posted for his temporary liberty in the aforesaid cases.

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 Such other just and equitable reliefs within the premises are also prayed for.

SO RESPECTFULLY PRAYED.

July 9, 2020, Cebu City for Lapu-Lapu City, Philippines.

LAWYER’S NAME

REQUEST FOR HEARING

The Branch Clerk of Court

MTCC - Branch 01
Justice Hall, Lapu-Lapu City
Email Address: ______________________

Sir:

Please, submit the foregoing __________________________________________________before

the Honorable Court for its consideration and approval on _____________________________ in the
morning sans further oral arguments.

Thank you.

Very Truly Yours,

Copy Furnished via e-mail:

___________________________________
City Prosecution Office
Justice Hall, Lapu-Lapu City
Email Address: ___________________

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