Republic of the Philippines

National Capital Judicial Region

METROPOLITAN TRIAL COURT
Manila, Branch 19

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus-
Crim. Case No. R-MNL-2020-03776-CR
For: Estafa

RAYMUND MANZANARES y PAVIA

alias RAYMUND,
VIVIEN MANZANARES y AMPIL alias VIVIEN
Both of Block 7 Lot 12 Verdant Heights,
Multinational Village, Parañaque City
CHRISTINE PITIQUEN y MALBAS alias TIN
2445 Rizal Avenue Brgy. 209, Tondo, Manila
Accused.
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MOTION TO REDUCE BAIL

We, the above-named accused in the above captioned case, by
ourselves, unto this Honorable Court, most respectfully averred:

1. That we are presently detained at the detention cell of the

Manila Police District for allegedly having violated the above-stated criminal
charge and the recommended amount of bail in the information for our
provisional liberty is Thirty Thousand Pesos (Php30,000.00) each.

2. That since we were arrested last August 12, 2020 and

subsequently brought before the Manila City Prosecutor’s Office for Inquest,
we were continuously detained up to the present which resulted in the
depletion of our finances, thus, we were reduced to mere beggars.

3. With our present situation, we will be constrained to borrow

money from our relatives and friends just to produce the amount needed to
post our respective bail.

WHEREFORE, in view of our present predicament especially during

this pandemic, we beg the kind indulgence of this Honorable Court and for
humanitarian considerations, the supposed Thirty Thousand Pesos
(Php30,000.00) amount of bail be reduced to Fifteen Thousand Pesos
(Php15,000.00) for each of us.

City of Manila, 08 September 2020.

RAYMUND P. MANZANARES VIVIEN A. MANZANARES

CHRISTINE M. PITIQUEN

NOTIFICATION
The Clerk of Court
MTC Branch 19
Manila

Greetings:

Please submit the foregoing motion immediately upon receipt hereof

for the kind consideration and approval of the Honorable Court without
further arguments.

RAYMUND P. MANZANARES VIVIEN A. MANZANARES

CHRISTINE M. PITIQUEN

Copy furnished:

Assigned Trial Prosecutor to

MTC Branch 19
Manila