REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

SIXTH JUDICIAL REGION
BAGO CITY
Branch 62

PEOPLE OF THE PHILIPPINES,

Criminal Case Nos. 4313 to 4315

- versus - For: Sexual Abuse in relation to
R.A. 7610

EDDIE L. BAILON J.R.,

Accused.

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MOTION TO RELEASE CASH BOND USED AS
BAIL)
The Accused, by counsel, respectfully states:

1. For his provisional liberty pending the trial of the above-

captioned cases, the Accused posted bail  in the amount of Five Hundred
Forty Thousand Pesos (P540,000.00) on September 21, 2018.

A copy of the Official Receipt is attached herein as Annex “A.”

2. On June 23, 2021, this Honorable Court acquitted the Accused

of the crimes charged in the Informations but found the same guilty of the
lesser offense of “Acts of Lasciviousness” for the actions that he took
against the three (3) minor complainants. This Honorable Court also directed
the Accused to pay the minor complainants Seventy Five Thousand Pesos
(P75,000.00) each or a total of Two Hundred Twenty Five Thousand Pesos
(P225,000.00).

3. On the same hearing day, the Accused, being qualified to apply

for probation, chose not to appeal his conviction and moved for the
suspension of the execution of his sentence pending his application for
probation by virtue of Presidential Decree No. 968 as amended by Republic
Act 10707.

4. By reason of the foregoing, the Accused humbly moves for the

release of the aforementioned cash bond that he posted before this
Honorable Court as he will use the money to pay the three minor

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complainants the adjuged amount of Seventy Five Thousand Pesos
(P75,000.00) each.

Relief

WHEREFORE,  in view of the foregoing, the Accused respectfully

prays to this Honorable Court that his cash bail bond in the amount of Five
Hundred Forty Thousand Pesos (P540,000.00) be released in his favor.

Other equitable reliefs are likewise prayed for.

Bacolod City for Bago City, May 26, 2021.

CATACUTAN & SINCO

LAW OFFICES
Counsel for the Accused
Door No. 4, 2nd Floor,
Esteban – Magdalena Bldg.,
Hernaez Street, Brgy 38, Bacolod City
Negros Occidental, 6100
Email Address: caslawoffices@gmail.com
Cell Phone No.: 0998-343-5104/0928-860-5361

By:

ACE JOSEPH B. CATACUTAN

PTR No. 7126822/01-04-18/Bacolod City
IBP No. LRN-028649/01-19-2018/
Negros Occidental Chapter
Attorney’s Roll No. 64091
MCLE Compliance No. V-0023218; 04-14-19

GABRIEL P. SINCO
PTR No. 7126821/ 01-04-18/Bacolod City
IBP No. LRN - 028650/ 01-19-2018/
Negros Occidental Chapter
Attorney’s Roll No. 67606
(Complied pending release of MCLE Comp. No.)

Copy furnished:

The Branch Clerk of Court

Regional Trial Court-Branch 62
Bago City, Negros Occidental.

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Atty. Ma. Christy E. Uriarte
The Honorable City Prosecutor
Hall of Justice, Bago City.
Greetings:

Please be informed that the foregoing motion shall be submitted for

the consideration and approval of this Honorable Court on ______.

Gabriel P. Sinco