Republic of the Philippines

National Capital Judicial Region

REGIONAL TRIAL COURT
Branch _____
Mandaluyong City

PEOPLE OF THE PHILIPPINES,

Plaintiff,
CRIM. CASE NO. R-MND-
CRIM. CASE NO. R-MND-
CRIM. CASE NO. R-MND-
- versus - CRIM. CASE NO. R-MND-
CRIM. CASE NO. R-MND-
CRIM. CASE NO. R-MND-

FOR : Rape by Sexual Assault

(Art 266-A par 2 of the
Revised
Penal Code as amended by
AAA R.A. No. 8353)

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

MOTION TO REDUCE BAIL BOND

COMES NOW, CICL AAA, through counsel unto this Honorable

Court most respectfully states:

1. That CICL is currently detained at Bahay pag-asa Youth

Development Center in Mandaluyong City Philippines for six (6)
counts of Rape by Sexual Assault under Article 266-A par. 2 of the
Revised Penal Code as amended by R.A. 8353;

2. That records of this case readily disclosed that the bail bond
recommended for the Assistant City Prosecutor of Mandaluyong
City for his temporary liberty is fixed at ONE HUNDRED
TWENTY THOUSAND PESOS (PhP 120,000.00) per count;

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 3. That CICL and his family is living way below poverty line on a hand
to mouth bases and he cannot in anyway defray the bail
recommended in the Information of this case;

4. Moreover, the challenges brought about by the pandemic further

crippled the already destitute finances of the CICL’s family. To
substantiate his claim, attached herewith is the Certificate of
Indigency issued by the Punong Baranggay of Baranggay Addition
Hills.

5. In view thereof, the CICL is seeking the kind indulgence of this

Honorable Court to Reduce the amount of the Bail Bond from ONE
HUNDRED TWENTY THOUSAND PESOS (PhP 120,000.00) per
count to SIXTY THOUSAND PESOS per count (PhP 60,000.00).

6. The accused and his parents personally undertake to appear before

this Honorable Court in each and every hearing of this case, as this
relief in equity is being sought for in order to allow the accused’s
temporary liberty by posting a bail bond commensurate to his means
and for humanitarian reasons.

PRAYER

WHEREFORE, premises considered, and in the interest of substantial

justice, it is most respectfully prayed of this Honorable Court that the motion to
reduce bail bond be granted.
Mandaluyong City, 02 May, 2022

PUBLIC ATTORNEY’S OFFICE

Department of Justice
Ground Floor, Old Hall of Justice
Maysilo Circle, Boni Avenue,
Mandaluyong City

By:

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 NOTICE OF HEARING

Branch Clerk of Court

Regional Trial Court
Mandaluyong, City

GREETINGS:

Please submit the foregoing motion for the kind consideration and approval of
this Honorable Court immediately upon receipt hereof.

COPY FURNISHED: