Republic of the Philippines

REGIONAL TRIAL COURT

FIRST JUDICIAL REGION
Branch 7
Baguio City

PEOPLE OF THE PHILIPPINES,

Plaintiff,
CRIMINAL CASE NO. 144-A
-versus- For: RECKLESS IMPRUDENCE
RESULTING TO DAMAGE TO
PROPERTY
JUAN LLOYD CRUZ
Accused.
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MOTION FOR REDUCTION OF BAILBOND

The accused, JUAN LLOYD CRUZ, through the undersigned counsel in the above-
entitled case, and to this Honorable Court respectfully states that:

1. The accused, JUAN LLOYD CRUZ, is charged for RECKLESS IMPRUDENCE

RESULTING IN DAMAGE TO PROPERTY now pending before this Honorable
Court with Criminal Case No. 144-A;

2. That the recommended bond for his provisional liberty is in the amount of FIFTY
THOUSAND PESOS (Php50,000.00);

3. That accused, considering that he is at this time suffering from financial

constraints, can only produce the amount of THIRTY THOUSAND PESOS
(Php30,000.00) CASH;

4. That accused needs his temporary liberty in order for him to gather all the
necessary evidence for his proper defense from this baseless accusation which
he cannot do if inside the prison;

5. That the accused together with his family is a permanent resident of this
Province, particularly at Cogcoga, Km. 3, La Trinidad, Benguet and therefore the
possibility for him to jump bail is too nil;

6. That the accused promise to attend all scheduled hearing in the above entitled
case and obeys all 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 Php50,000.00 will be
reduced to Php30,000.00 CASH.

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

Baguio City, for La Trinidad, Benguet, Philippines, this 3th day of February, 2011.

ATTY. SHANA LAURIE P. LOCANO

Attorney for Defendant
Rm. 204 Igorot Jewel Bldg.
Km. 4, La Trinidad, Benguet
PTR NO. 1986578; 01-17-11
IBP OR NO. 987173; 01-17-11
ROLL NO. 12345; 07-20-10

NOTICE AND REQUEST

THE CLERK OF COURT

RTC Branch 7, Baguio City

Greetings!

Please submit the foregoing motion to the Honorable Court immediately upon
receipt thereof for its consideration and approval without further arguments.

ATTY. SHANA LAURIE P. LOCANO

Copy Furnished:
Office of the City Prosecutor
Baguio City, Philippines