Republic of the Philippines

Fourth Judicial Region

REGIONAL TRIAL COURT
Branch 55
Lucena City

THE PEOPLE OF THE PHILIPPINES,

Plaintiff,
Criminal Case No.: 2015-1730
For: Estafa

-versus-

CARLO JAMES GABRIEL y CASTRO

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

MOTION TO REDUCE BAIL

COMES NOW, Accused, CARLO JAMES GABRIEL y CASTRO,

assisted by the undersigned counsel from the Public Attorney's Office, to
this Honorable Court, most respectfully avers that:

1. Accused is charged of the crime of Theft punished under the

Revised Penal Code;

2. The bail set for the provisional liberty of the accused is Twenty
Thousand Pesos (P20,000.00);

3. Accused is currently detained in Mauban Municipal Police Sta-

tion, attached herein is the Certificate of Detention of CARLO
JAMES GABRIEL y CASTRO dated 25 August 2023 as Annex
“A”;

4. The accused prays that the bail fixed by the Honorable Court be
reduced to Ten Thousand Pesos (P10,000.00);

5. Prior to his arrest, accused works as a microfinance debt-collec-

tor . Income from said job is not sufficient to support his 1 (one)
child and their day-to-day needs as he is solely providing for the
needs of his child;

6. The amount of the required bail, Twenty Thousand Pesos

(P20,000.00), is burdensome on the part of the accused and his
family considering that he is the sole breadwinner of the family.

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 PRAYER

WHEREFORE, premises considered, for the kind and

humanitarian consideration, it is respectfully prayed that the bail required
for the provisional liberty of the accused be reduced to Ten Thousand
Pesos (P10,000.00).

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

Lucena City, 29 August 2023.

Respectfully submitted,

PUBLIC ATTORNEY’S OFFICE

Lucena District Office
3/F Midtown Pavilion Building
Quezon Avenue cor. Leon Guinto Street
Lucena City
By:

ERICK JOHN PAUL P. SAYSAY

Public Attorney II
Roll of Attorneys No. 75601
IBP OR No. 305478 / 27 January 2023
MCLE Compliance No. VII-0024389

Noted by:

CARMI D. MAGSINO-ARAZA
District Public Attorney

Copy furnished:

Fiscal Reynaldo A. Ariola

Trial Prosecutor
RTC Branch 55
Lucena City

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