Republic of the Philippines

First Judicial Region

REGIONAL TRIAL COURT
Branch 43, Dagupan City

THE PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- CRIMINAL CASE NO. 2018-0337-D

MAXIE GARCIA,
Accused.
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URGENT EX-PARTE MOTION TO LIFT ORDER OF

ARREST AND POSTING OF BOND

Accused, by himself, and unto this Honorable Court most respectfully states
that:

1. On 14 August 2018, the Honorable Court due to the absence of the accused
during his arraignment and pre-trial forfeited his cashbond in favor of the
government. Accordingly, a Warrant of Arrest was issued against the accused and
posting of bond in the amount of Four Thousand Pesos (P4,000.00.).

2. Accused respectfully apologizes to the Honorable Court for his failure to

appear at the arraignment and pre-trial. On said date, the place of residence of
the accused in Macabito, Calasiao, Pangasinan was experiencing floods due to
Habagat. In fact, he tried to come to this Honorable Court, however, no passenger
jeepneys were plying their route.

3. The accused has no intention to avoid or delay the prosecution of the case
but it is only for the above reason that caused his failure to attend the hearing on
August 14, 2018.

4. For the above reason, accused respectfully prays that the warrant of arrest
and posting of his cash bond be lifted. The accused has already posted bond in the
amount of P2,000.00. He could hardly put up the new bond for his provisional
liberty. He undertakes to be present during subsequent hearing of the case and at
all times when the Honorable Court so requires.

WHEREFORE, it is most respectfully prayed of this Honorable Court to

grant this motion.

Other just and equitable reliefs are likewise prayed for.

 Dagupan Ctity; September 3, 2018.

MAXIE D. GARCIA
Accused

REQUEST FOR & NOTICE OF HEARING

THE BRANCH CLERK OF COURT

Regional Trial Court
Branch 43, Dagupan City

PROS. MARCELO C. ESPINOZA

Senior Assistant Provincial Prosecutor
OFFICE OF THE PROVINCIAL PROSECUTOR
Dagupan City

Greetings!

Please submit the foregoing motion to the Honorable Court for its immediate
consideration and approval without further oral argument.

ACCUSED