Republic of the Philippines

REGIONAL TRIAL COURT

Second Judicial Region
Branch 31
Cabarroguis, Quriino

PEOPLE OF THE PHILIPPINES

CRIM CASE NO. 393-2019
plaintiff,
FOR
-versus-
QUALIFIED THEFT
JOSEPH CABOTAJE y CARDENAS
Accused.
x----------------------------------------------------------x
MOTION TO REDUCE BAIL

Accused, through counsel, by way of a special appearance solely for this

purpose, respectfully alleges:

1.That the accused has been charged with QUALIFIED THEFT and that
the bail for his provisional release has been set at FORTY TOUSAND
(Php 40,000.00 pesos) ;

2. That the accused is a poor fellow of very limited means such that it is
impossible for his to pay the full amount of his bond and is therefore
constrained to request for a reduction of the amount of bail;

3. That it would be advantageous to everyone if he be given temporary

liberty thereby allowing his to continue with his gainful employment and
as head of the family with one (1)dependent;

4. As such, accused appeals to the mercy and compassion of

this Honorable Court and respectfully requests that his bail be reduced
to TWENTY ONE THOUSAND (P21,000.00) PESOS;

5.That this motion for reduction of bail is being filed without prejudice to
any other remedy which may be available to the accused and that the
accused expressly reserves the right to question the legality of
the issuance of the search warrant or his warrantless arrest if the
circumstances would so warrant.

WHEREFORE, accused respectfully prays that her bail be reduced to

TWENTY ONE THOUSAND (P21,000.00) PESOS

Other relief just and equitable are likewise prayed for.

Diffun, Quirino, Philippines, November 12, 2019.

MA. KAREN A. BALDONADO-GUILLERMO

Counsel of the Accused
 NOTICE OF HEARING

THE BRANCH CLERK OF COURT

RTC BRANCH 31

Cabarroguis, Quirino

Greetings!

Please submit the foregoing motion to the Honorable Court on

November 18, 2019 at 8:30 in the morning for its favorable
consideration and approval.

MA. KAREN A. BALDONADO-GUILLERMO

Counsel of the Accused

Copy furnished by personal service:

OFFICE OF THE PROVINCIAL PROSECUTOR