Republic of the Philippines

REGIONAL TRIAL COURT

Second Judicial Region
BRANCH 20
Cauayan City, Isabela

PEOPLE OF THE PHILIPPINES

Plaintiff,
Criminal Case No. 20-6864
-versus -

TOMAS FERNANDEZ,
Accused
x----------------------------------------x

MOTION FOR RECONSIDERATION

COMES NOW the accused thru the undersigned

bondsman and unto this Honorable Court most respectfully
avers;

1. That the herein movant is the bondsman of the above-

named accused in the above-entitled case;

2. The promulgation of the accused was set on August 24,

2018;

3. Regrettably however, the accused failed to appear for his

scheduled promulgation on said date for reasons beyond
his control much less of his bondsman, the Alpha
Insurance and Surety Company, Inc., reason for which,
on April 02, 2019 the undersigned received an Order of
the Honorable Court giving herein bondsman a period of
thirty (30) days to produce the body of the accused and
to show cause why the bail bond posted for the
temporary liberty should not be confiscated;

4. However, with the forbearance of the Honorable Court,

the undersigned hereto moved for the reconsideration of
the March 19, 2019 Order on the ground that the movant
did not receive a copy of the notice of hearing stating
that the accused Tomas Fernandez is required to attend
his hearing scheduled last August 24, 2018;
 5. This motion is made in good faith and not intended to
delay the proceedings of the instant case;

6. Thus movant prays for the indulgence of this Honorable

Court and asks for its reconsideration to set aside Court
Order dated March 19, 2019 and asks an extension of
thirty (30) days to locate the body of the accused and to
lift the warrant of arrest issued against him;

7. Thus, if the accused had been successfully found, the

movant guarantees that the accused will be surrendered
to the custody of the Honorable Court.

WHEREFORE, it is most respectfully prayed to this

Honorable Court that the ORDER dated March 19, 2019 be
reconsidered and set aside.

Cauayan City, Isabela. April 29, 2019.

ALPHA INSURANCE & SURETY COMPANY, INC.

By:

MYRNA FELY D. RESURRECCION

Bondsman

THE CLERK OF COURT

Regional Trial Court
Branch 20
Cauayan City, Isabela

Greetings:
Kindly submit the foregoing motion immediately upon
receipt hereof for its kind consideration and approval.

ALPHA INSURANCE & SURETY COMPANY, INC

By:

MYRNA FELY D. RESURRECCION

Bondsman

Copy Furnished:

OFFICE OF THE PUBLIC PROSECUTOR

Cauayan City, Isabela