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REPUBLIC OF THE PHILIPPINES

THIRD JUDICIAL REGION


MUNICIPAL TRIAL COURT IN CITIES
Cabanatuan City

THE PEOPLE OF THE PHILIPPINES,


Complainant,

- versus - CRIMINAL CASE NO. 99185


FOR: Violation of BP 22

PRESSY QUINN VILLEZCA BLANCA,


Accused,
x--------------------------------x

MOTION TO POST AND REDUCE BAIL

The accused, PRESSY QUINN VILLEZCA BLANCA, unto this


Honorable Court respectfully states that:

1. The accused, PRESSY QUINN VILLEZCA BLANCA, is being


charged for Violation of B.P. 22 now pending before this Honorable
Court with Criminal Case No. 99185;

2. The accused is currently detained at the Gen. M. Natividad Police


Station in relation to the above-mentioned case;

3. That the recommended bail for her provisional liberty is in the


amount of SIX THOUSAND PESOS (Php6,000.00);

4. That the accused, considering that she is at this time suffering from
financial constraints, and she is not affluent in life and currently has
unstable source of income due to the pandemic can only produce the
amount of THREE THOUSAND PESOS (Php3,000.00) CASH;

5. That the accused needs her temporary liberty in order for her to
work to support her family and to gather all the necessary evidence
for her proper defense from this case which she cannot do if inside the
prison;

6. That the accused together with her family are permanent residents of
this Province of Nueva Ecija, particularly at Purok Talisay, Municipality
of General Mamerto Natividad, and therefore the possibility for her to
jump bail is too nil;

7. That the accused promises to attend all scheduled hearing in the


above-entitled case and obey all the processes of this Honorable
Court.

PRAYER

WHEREFORE, premises considered and in view of the foregoing, it


is respectfully prayed to the Honorable Court that the recommended bond
of Php6, 000.00 will be reduced to Php3, 000.00 CASH.

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

General M. Natividad, Nueva Ecija, Philippines. April 13, 2023.

PRESSY QUINN VILLEZCA BLANCA


Accused
NOTICE AND REQUEST

THE CLERK OF COURT


MTCC Branch I
Cabanatuan City

Greetings!

Please submit the foregoing motion to the Honorable Court


immediately upon receipt thereof for its consideration and approval
without further arguments.

PRESSY QUINN VILLEZCA BLANCA

Copy Furnished:

OFFICE OF THE CITY PROSECUTOR


Cabanatuan City, Nueva Ecija
REPUBLIC OF THE PHILIPPINES)
Province of Aurora ) ss
Municipality of Dingalan )

AFFIDAVIT OF UNDERTAKING

I, CESAR MOYA SAHUL, Filipino, of legal age, married, and a


resident of Barangay Caragsacan, Dingalan, Aurora, after having duly
sworn to in accordance with law, hereby depose and state, THAT:

1. I am the accused in Criminal Case No. 900 for RECKLESS


IMPRUDENCE RESULTING IN HOMICIDE AND DAMAGE TO
PROPERTY pending before the Honorable Court;

2. I have posted a cash bond in the amount of THIRTY THOUSAND


PESOS (PHP30,000.00) for my provisional liberty;

3. I hereby undertake to appear before the proper Court whenever I will


be required by the Court to do so;

4. Failure on my part to appear at the trial without justification despite


due notice shall be deemed as express waiver on my part to be
present on the date specified in the notice. In such case, the trial may
proceed in my absence;

5. I shall surrender myself for the execution of the final judgment of the
Honorable Court;

6. I am executing this affidavit to attest to the truth and veracity of the


foregoing document and as whatever legal purpose it may serve.

IN WITNESS WHEREOF, I have hereunto set our hand this 29th day of
September 2022 in Dingalan, Aurora.

CESAR MOYA SAHUL


Affiant
SUBSCRIBED AND SWORN TO before me this 29th of September
2022 in Dingalan, Aurora.

ATTY. QUEEN JANE TADEJA ALDAVE


Counsel for the accused
PTR NO.: 6411382, May 19, 2022 Dingalan, Aurora
IBP OR NO.: 189575, May 4, 2022, Nueva Ecija
Roll Number: 76089, May 4, 2022
Admitted to the Philippine Bar on May 4, 2022
queenjanetadeja.aldave2121@gmail.com/ 09566971432
Dingalan, Auroa

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