Republic of the Philippines

METROPOLITAN TRIAL COURT

National Capital Judicial Region
BRANCH 155, PASIG CITY

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO:

M-PSG-23-00145-CR

FOR: Violation of BP 22
-versus –

LOUIE MARK TAPIA TOLENTINO

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

MOTION TO REDUCE BAIL

Accused LOUIE MARK TAPIA TOLENTINO, assisted by the Public
Attorney’s Office (PAO), and unto this Honorable Court, most respectfully state
the following:

1. He is charged with the crime of violation of Batas Pambansa bilang 22. The
recommended bail is fixed at Twenty Four Thousand Pesos (PhP 24,000).
2. On November 17, 2023, the accused

3. However, both accused are currently detained and have no financial

capability to post the amount of bail initially fixed by the prosecution.

4. Thus, both accused are kindly pleading to the Honroable Court to allow
them to post bail in the amount of Fifteen Thousand Pesos (PhP 15,000)
each.

5. If granted bail at a reduced amount, the two accused guarantee that they
will abide by their bail undertaking, including the requirement that they
have to be present in all court hearings, as well as coordinate with the
court and counsel while the case is ongoing.

WHEREFORE, premises considered, and in the interest of justice, it is respectfully

prayed of this Honorable Court that the amount of bail for the temporary liberty of
accused EDGAR TAMONDONG y QUITANO and EUGENE IMPAG IBANEZ, be
reduced to FIFTEEN THOUSAND PESOS (PhP 15,000) each to be paid in cash.

Other just and equitable reliefs are likewise prayed for.

Respectfully submitted.

November 9, 2023, Pasig City.

DEPARTMENT OF JUSTICE

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 PUBLIC ATTORNEY’S OFFICE
rd
3 Floor, Bahay Aruga -Pasig Social Welfare Development
Eusebio Building, City Hall Compound
Caruncho Avenue, Brgy. San Nicolas, Pasig City

by

ATTY. MARIA GICEL T. CAMBRI

Public Attorney II
Roll of Attorneys No. 70275
IBP Member No. 234215 / June 13, 2022
MCLE Compliance No. VI-0029131

NOTICE

Regina C. Fabellar
Branch Clerk of Court
MTC 155, Pasig City

GREETINGS:

Kindly submit the foregoing Motion for the kind consideration of the
Honorable Court.

ATTY. MARIA GICEL T. CAMBRI

Copy furnished:

SACP LUTHER T. PONPON

Public Prosecutor
Office of the City Prosecutor
7th Flr., Bulwagan ng Katarungan
City Hall Complex, Pasig City

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