Republic of the Philippines

REGIONAL TRIAL COURT OF BULACAN

Third Judicial Region
BRANCH 1234

xxxx,
Complainants,

- versus -
NPS DOCKET NO.:
FOR: Grave Threat, Alarm and
Scandal and Viol. of RA 10591
xxxx,
Respondent.
x-----------------------------------x

URGENT MOTION TO FIX BAIL

RESPONDENT, thru the undersigned Attorney and unto this

Honorable Court, respectfully aver:

1. Respondent in the above-entitled case pending before the

Provincial Prosecutor is being complained for Grave Threat,
Alarm and Scandal and Viol. of RA 10591, all bailable
offenses;

2. Respondent is presently detained at xxx Municipal Police Station,

Balagtas, Bulacan in relation to above-mentioned case, Attached
herein as Annex “1” is a copy of a Certificate of Detention;

3. Respondent wishes to post his bail bond for his provisional

liberty, pending preliminary investigation pursuant to Section 17
Paragraph C of Rule 114 of the Revised Rules of Court;

4. In the event that the Motion to Fix Bail is granted, the accused
humbly prays that the same be reduced.

5. Respondent is an eighty (80) year old senior citizen who is also

suffering from diabetis and hypertension, making his prolonged
stay as a detention prisoner detrimental to his health and well
being, hence the urgency of the instant motion.
WHEREFORE, premises considered, herein respondent, invoking his
constitutionally guaranteed right to bail, respectfully prays that the bail
bond for his provisional liberty be fixed and further prays for the
reduction of the same.

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

Respectfully submitted.

City of Malolos, Bulacan.

26 March 2018.