Republic of the Philippines

REGIONAL TRIAL COURT

2ndJudicial Region
Branch 08
APARRI, CAGAYAN

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO. II-15687

-versus- FOR:

RAMIL MILLAMINA VIOL. OF R.A 10591

Accused.
X-------------------- X

MOTION TO REDUCE BAIL

UNTO THIS HONORABLE COURT, Accused, through counsel,

most respectfully aver that:

1. The above-named accused was charged with violation of

violation of R.A 10591 otherwise known as Comprehensive
Law on Firearms and Ammunition;

2. The accused was arrested on March 2, 2021 and is presently

being detained at Sta. Teresita District Jail, Sta. Teresita,
Cagayan;

3. The Honorable Court fixed the bail for the provisional liberty of
the accused of the accused at One Hundred Twenty Thousand
pesos (P120,000.00);

4. The accused is an indigent person as evidenced by the a

Certification issued by the Office of the Barangay Captain of
Villa Leonora, Buguey, Cagayan. Thus, the accused does not
have the financial capacity to post bail bond in the amount fixed
by the court;

“ The Certificate of Indigency is hereto attached as Annex 1”

5. Thus the accused through the undersigned

1 counsel, most
respectfully begs of this Honorable Court that this bail bond be
reduced to SIXTY THOUSAND PESOS (P60,000.00);
 6. The accused is a poor fellow of limited means and has no
valuable properties. Thus, he is fervently praying of this
Honorable Court that the amount of bail be fixed in the amount
aforementioned;

7. Accused is a good member of the community, and a resident of

Villa Leonora, Buguey, Cagayan and the probability of flight is
nil;

8. Accused has not been previously convicted of any crime and

have no pending case in any judicial or quasi-judicial body in
the Philippines;

9. Accused will undertake to be present when this case is called in

Court;

PRAYER

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

humanitarian consideration, it is most respectfully prayed of this Honorable
Court that this motion be granted and that the amount of bail for the
provisional liberty of the accused be reduced to SIXTY THOUSAND
PESOS (P60,000.00).

Other reliefs, just and equitable under the circumstances are likewise
prayed for.

Most respectfully submitted.

Aparri Cagayan, Philippines, March 3, 2021.

Atty. Orlando B. Bareng Jr.

Door 1, Martinez Building, Centro East, Sta. Teresita, Cagayan
Roll No. 73345, 06-19-2019
PTR No. 10897750/ 01-11-2021/ CGYN
IBP Mem. O.R No. 1712/ 01-08/2021/CGYN
Cp. No: 0905-6928-114
barengorlando@yahoo.com.ph
Admitted to BAR(2019): MCLE not yet required

2
 NOTICE OF HEARING

PROVINCIAL PROSECUTOR
PROVINCIAL PROSECUTION OFFICE
APARRI, CAGAYAN

THE CLERK OF COURT

REGIONAL TRIAL COURT
BRANCH 8
APARRI, CAGAYAN

Greetings:

Please submit the foregoing Motion for the consideration and approval of
this Honorable Office on March ___, 2021 at ________or as soon as this
may be heard.

ATTY. ORLANDO B. BARENG JR

Copy Furnished:

OFFICE OF THE PROVINCIAL PROSECUTOR

APARRI, CAGAYAN