Republic of the Philippines

Court
FIRST Judicial Region
Branch _____
City of Baguio

People of the Philippines, NPS No. I-17-INQ-21-1053

Plaintiff, CRIMINAL CASE NO._______
-versus- FOR:
PHILMORE BIANG y BONUAN VIOLATION OF R.A. 10591
Accused.
X-----------------------------------X

MOTION TO REDUCE BAIL

UNTO THIS HONORABLE COURT comes the Accused, through

counsel, most respectfully and humbly aver:

1. That aboved named Accused is charged with Illegal Possesion of Firearm as

defined under RA 10591;

2. That Accused is presently detained at Station 7 Baguio City Police Station,

pending the hearing of this case, and that this case has been raffled to this
sala;

3. That the Resolution of the Honorable Office of the City Prosecutor has fixed
the bail of the accused at PHP 80,0000.00 (Eighty-Thousand Pesos);

4. That the recommended bail for the Violation of RA 10591 specifically for
mere unlawful possession of Firearms and Ammuniation (Section 29. {a}),
as based on Department of Justice Department Circular No.13 Bail Bond
Guide of 2018 is PHP 80,000.00

5. That the bail amount recommended though strict to the letter of the law does
not echo the spirit of the law; which is tantamount to denial of bail. Wherein
 if the right to bail exists, it should not be rendered nugatory for the people
who has less in wealth such us the accused and especially in our current
trying times in the pandemic;

6. That the accused is not affluent in life who earns as a mere driver for
minimal wage, and is also burdened to share in his earnings in taking care of
his family;

7. That due to the recent pandemic and economic decline of the Philippines, the
accused has further lost much savings and earnings in trying to survive
COVID19;

8. That the accused is humbly requesting for the reduction of bail to

PHP40,000.00 (Forty-Thousand Pesos) which is within the humble
capabilities of the accused to muster;

9. That it is within the wisdom of this Court that has the final say to what the
Bail amount would be as provided for by law;

10. That the accused is a good member of the community, and a resident of the
City of Baguio whose family also resides therein, and the probability of
flight is nil;

PRAYER

WHEREFORE, premises considered, in the interest of justice and for

humanitarian consideration in this trying times, it is most respectfully prayed of
this Honorable Court that this motion to reduce bail be granted.

Other Reliefs, just and equitable under the circumstances as likewise

prayed for;

Most Respectfully Submitted.

2 August 2021. ___________________, Philippines

Atty.______________________