Republic of the Philippines

REGIONAL TRIAL COURT

Fourth Judicial Region
Branch ____
San Mateo, Rizal

PEOPLE OF THE PHILIPPINES,

-versus-

CRIM. CASE NO. _______ to _______

f f f,
Accused.
x------------------------------------------x

MOTION TO ALLOW BAIL

PENDING APPROVAL
OF PROBATION

Movant, ghfhgfh, assisted by the undersigned counsel and unto this Honorable
Court most respectfully manifest and states that:

1. Movant was charged for Violation of two counts of Section 5 and one (1)
count of Section 11 of RA 9165 and plea bargained to the lesser offense of
Section 12 of the same law in accordance with A.M. 18-03-16-SC for each
case;

2. On the same day, the Honorable Court sentenced movant to suffer a straight
penalty of imprisonment of one (1) year and to pay a fine of ten thousand
(P10,000.00) pesos for each case;

3. Movant filed his Application for Probation and the same was given due course
on September 30, 2020;

4. Movant has already paid the fifty thousand (P50,000.00) pesos fine imposed
on him by the Honorable Court as evidenced by the Official Receipt No.
5667057D dated April 26, 2021. A copy of which is hereto attached and
marked as Annex “A”;

5. Section 24, Rule 114 of the Rules of Court states that:

“Sec. 24. No bail after final judgment; exception- an accused shall not be
allowed bail after the judgment has become final, unless he has applied
for probation before commencing to serve sentence, the penalty and the
offense being within the purview of the Probation Law. In case the
 accused has applied for probation, he may be allowed temporary liberty under
his bail, but if no bail was filed or the accused is incapable of filing one, the
court may allow his release on recognizance to the custody of a responsible
member of the community. In no case shall bail be allowed after the accused
has commence to serve sentence. (Emphasis supplied)”

6. Movant is eligible under the exception as she has filed her application for
probation within the reglementary period and the judgment has not yet
become final;

7. Movant has no other pending cases as evidenced by the Certification issued

by the Office of the Clerk of Court dated April 26, 2021 attached herein as
Annex “B”;

8. Movant belongs to an indigent family, a copy of the Certificate of Indigency

from Barangay Banaba, San Mateo, Rizal is hereto attached and marked as
Annex “C”;

9. It is therefore, prayed that the movant be allowed post bail in the amount to
be determined by the Honorable Court. He undertakes to be present in all
processes of the Probation Office up to the full termination of the Probation
period.

WHEREFORE, premises considered, after due notice and hearing and after
assessment of the evidence of the State, it is respectfully prayed for that the accused be
allowed to post bail.

Other reliefs that are just and equitable are likewise prayed for.

San Mateo, Rizal, April 27, 2021.

ATTY. jksdhfkjhsdklfahkfklasjhdfklsjh
Public Attorney II

NOTICE

The Branch Clerk of Court

Regional Trial Court
Branch
Fourth Judicial Region
San Mateo, Rizal

G R E E T I N G S:

Due to urgent purpose of the foregoing motion for the movant, kindly submit the
foregoing motion for the consideration and approval of the Honorable Court.

ATTY. jkhwekrjhwkejhfksljd

Copy Furnished:

Trial Prosecutor
San Mateo, Rizal