REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT IN CITIES

ILOILO CITY
BRANCH 1

IN THE MATTTER OF THE PETITION TO

POST BAIL BOND AND MOTION TO REQUEST SPL. PROC. # 54(19)
FOR REDUCTION FOR THE DETAINEES “ DIRECT ASSAULT,
DENNIS ALIMPUNGAT Y PROTUSADA, ALLAN ALIMPUNGAT Y
SERVANTES AND RONNIE CADIZ Y SAMPANI, DISOBEDIENCE TO AN AGENT OF
PERSON IN AUTHORITY”

ATTY. ANNETTE NIETES-GENGOS

PETITIONER.
X - - - - - - - - -- - - - - - -- - - - - - -- - - - - - - -- - -- - - - - - - - --X

MOTION TO RELEASE CASH BOND

THE UNDERSIGNED COUNSEL and PETITIONER , to this Honorable Court respectfully

submits: That-

1) On 10 April 2019, this Honorable court issued an Order of Release for all the three
respondents who were then detained upon their filing of cash bonds for their provisional
liberty, as follows:

ALLAN ALIMPUNGAT Y SERVANTES

O.R. No. AMOUNT CRIME
5385111 Php 18, 000.00 Direct Assault
5385111 Php 1, 500.00 Alarms and Scandals
5385111 Php 1, 500.00 Disobedience to an Agent
of person in Authority

DENNIS ALIMPUNGAT Y PROTUSADA

O.R. No. AMOUNT CRIME
5385114 Php 18, 000.00 Direct Assault
5385115 Php 1, 500.00 Alarms and Scandals
5385115 Php 1, 500.00 Disobedience to an Agent
of person in Authority

RONNIE CADIZ Y SAMPANI

O.R. No. AMOUNT CRIME
5385119 Php 18, 000.00 Direct Assault
5385118 Php 1, 500.00 Alarms and Scandals
5385117 Php 1, 500.00 Disobedience to an Agent
of person in Authority

Copies of the information for each of the above-mentioned detainee are hereto attached, for reference.

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 2. Consequently, a Resolution was issued by the Iloilo City Prosecution Office, a copy of which is
hereto attached as ANNEX “A”, for which an Information was issued for each of the detainee, a copy of
which is hereto attached as ANNEX “B”, ANNEX “C” AND ANNEX “D” and were assigned as crim. Cases
Nos. S-303-19 and S-304-19 which was heard at the Municipal Trial Court In Cities, Branch 4;

3. Subsequently, the cases against the three now accused, were dismissed by the MTCC Branch,
a copy of the Dismissal and the Entry of Final Judgment are hereto attached as ANNEX “E” and ANNEX
“F”;

4. All three accused were able to claim the release of cash bond they posted for alarms and
scandals, but that for Direct Assault and Disobedience to an Agent of Person in Authority were not
released by reason that and order by this Honorable Court was required by the Office of the Clerk of
Court of the Municipal Trial Courts for such release because the MTCC-Branch 4 cannot issued such
Order since only the 2 crimes were heard and raffled to that court;

5. There having been no finding in the Resolution for Direct Assault for which no information for
each accused was issued, there is a need for this Honorable Court, to issue such order for the release of
the cash bond the accused posted as above-mentioned in their favor or to the favor of their Attorney-in-
fact, when applicable.

WHEREFORE, accused respectfully pray that an order be issued by this Honorable court for the
release of cash bond each posted under the Official Receipt above-stated for Direct Assault.

Other reliefs, just and equitable are prayed.

RESPECPTFULLY SUBMITTED. Iloilo City, this _____________

ANNETTE D. NIETES-GENGOS
Counsel for the Petitioner
NIETES-GENGOS, LABORTE-ILDESA & ARANETA Law Offices
2F, ATM Business Center, Cor. Jalandoni-Ledesma Sts., IC
Tels. (033) 3363954, 5092755 email: allportia@yahoo.com
PTR OR NO. 6422293/ 1.03.2019 Iloilo City
IBP OR NO. 072642 /1.10.2019/ Iloilo City
Roll No. 38153/
MCLE Compliance No. V-0011377 (6th complied on 3/28/2019)
TIN 191-774-638

NOTICE OF HEARING

The Clerk of Court

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MTCC Branch 1, Iloilo City

Greetings:

Kindly submit the foregoing Motion for the consideration and approval of the Honorable
court.

ANNETTE D. NIETES-GENGOS
Copy furnished:
The Iloilo City Prosecution Office
2nd Flr., Hall of Justice Bldg., Iloilo City
With Attention:

Asst. City Prosecutor VALERIE ALOVA

Received by _____________________ date____________

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