Republic of the Philippines

National Capital Judicial Region

METROPOLITAN TRIAL COURT
Branch 62
Makati City

THE PEOPLE OF THE PHILIPPINES,

-versus- CRIMINAL CASE No. 386009

DEAN FRITZ BIHAG y COBREDO

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

MOTION FOR REDUCTION OF BAIL

COMES NOW the accused, by counsel, unto this Honorable Court,

most respectfully states THAT:

1. The accused has been charged for violation of Article 212 of

Act No. 3815, otherwise known as “the Revised Penal Code, as amended”
before this Honorable Court;

2. At present, accused is under detention since 26 October,

2015 at the detention cell of the PNP Regional Highway Patrol Unit –
NCR, Investigation Section, Camp Crame, Quezon City and
the recommended bail for his provisional liberty has been set at Twenty
Thousand Philippine Pesos (₱20, 000.00);

3. The accused desires to post the required bail bond.

However, having a very limited means considering that his only source
of income/ livelihood is being a bus conductor, he would not be able to
raise the entire amount of the recommended bail, thus, he is constrained
to request for a reduction of the amount of bail;

4. As such, accused appeal to the mercy and compassion of this

Honorable Court and respectfully requests that the recommended bail
bond for his temporary liberty be reduced to Ten Thousand Philippine
Pesos (₱10,000.00).

WHEREFORE, in view of the foregoing, it is most respectfully

prayed that the accused be allowed to post bail bond for the above-

Page 1 of 2
entitled case at a reduced CASH BOND in the total amount of Ten
Thousand Philippine Pesos (₱ 10,000.00).

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

RESPECTFULLY SUBMITTED.

Quezon City for Makati City, November 10, 2015.

JAMES CORWIN S. CUSTODIO

Counsel for Dean Fritz C. Bihag
Attorney’s Roll No. 63741
IBP No. 0988238; 01/09/2015; RSM Chapter
MCLE Compliance No. V – 0005492; 01/14/2015
PTR No. 0561241; 01/05/2015; Quezon City
2/F Mencorp Annex Building, 701 EDSA
corner New York Street, Cubao, Quezon City
Contact Nos. (02) 413-1422 • 0998-8514537
Email: jcorwin.custodio@gmail.com

NOTICE OF HEARING
and COPY FURNISH:

THE HONORABLE CLERK OF COURT

Metropolitan Trial Court – Branch 62
Makati City

THE OFFICE OF THE CITY PROSECUTOR

Makati City

Greetings:

Please be informed that the undersigned hereby request to submit

the foregoing motion for the consideration and approval of the
Honorable Court immediately upon its receipt by the Honorable Clerk of
Court.

JAMES CORWIN S. CUSTODIO

NO OBJECTION:

THE OFFICE OF THE CITY PROSECUTOR

Makati City

Page 2 of 2