REPUBLIC OF THE PHILIPPINES

Third Judicial Region

MUNICIPAL TRIAL COURT IN CITIES
City of San Jose Del Monte
Province of Bulacan

TO THE EXECUTIVE JUDGE

PEOPLE OF THE PHILIPPINES,

Plaintiff

-versus- CRIM. CASE NO. 11-0014

FOR: UNJUST VEXATION

JANET V. SINOY
Accused.
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URGENT MOTION TO POST AND FIX BAIL

ACCUSED, through Counsel De Officio, unto this Honorable Office of the

Executive Judge most respectfully states:

1. That the above mentioned respondents were charge of the crime of

Disobedience, Direct Assault, Slander by Deed, Usurpation of Authority
and Violation of LTO Code RA 4136 1, which incident allegedly took place on
March 27, 2016 pending before the Office of the City Prosecutor of San Jose Del
Monte, Bulacan.

2. That the said respondents were allegedly caught in flagrante delicto

and were arrested without warrants and currently detained at Bureau of Jail
Management and Penology (BJMP) of San Jose Del Monte, Bulacan.

3. That the respondents were charge of a crime which are bailable.

Pursuant to Rule 114 Section 17 paragraph C of the Rules of Court, any person
who is not yet charged in court may apply for bail with any court in the
province, city, or municipality where he is held.

4. Respondents requested for Preliminary Investigation and it might take

several days or weeks before the Honorable Prosecutor’s Office can issue of
release the said Resolution.

5. Moreover, Respondent Joveth B. Purisima is one of the graduating

students of La Concepcion College, CSJDM, and is set to March on April 19,
2016.

4. Considering that Respondents have not yet been charge in court

and the crime for which the respondents were charge are bailable. The
respondents move that this Honorable Office of the Executive Judge to admit
1
A copy of the Judicial Affidavits (Complaint-Affidavit) and all other documents pertaining to the
Complaint is hereto attached as Annex “A to A-14”
and fix the amount of bail, so herein respondents could post bail for their
provisional liberty pending the issuance of the Resolution of the Office of the City
Prosecutor and Respondent Joveth B. Purisima could attend his graduation rites.

PRAYER
WHEREFORE, PREMISES CONSIDERED, it is respectfully prayed of
this Honorable Office of the Executive Judge that the respondents be allowed to
post bail pending Resolution of the Prosecutors Office of the above entitled case
before the Office of the City Prosecutor of San Jose del Monte Bulacan and fixing
the amount of bail thereof.

Other relief and remedies just and equitable under the premises are likewise
being prayed for.

San Jose Del Monte, Bulacan. April 4, 2016.

Assisted by:

PUBLIC ATTORNEY’S OFFICE

City of San Jose Del Monte, Bulacan District Office
2nd Floor, Hardware 2000 Building, Brgy. Graceville
City of San Jose Del Monte, Bulacan

By:

MAY FLOR C. ABUEDO

Public Attorney-I
ROLL NO. 58132
MCLE COMPLIANCE NO. V- 0009175 dated July 23, 2015
IBP NO. 1025870 (Albay Chapter) dated February 18, 2016

NOTICE OF HEARING
THE CLERK OF COURT
MTCC-San Jose Del Monte, Bulacan

GREETINGS:

Please take notice that this Petition for Bail shall be submitted for the kind
consideration and approval of this Honorable Court on April 12, 2016 at 8:30
in the afternoon.

MAY FLOR C. ABUEDO

COPY FURNISHED:

Office of the City Prosecutor

City of San Jose Del Monte, Bulacan