Republic of the Philippines

COURT
____th Judicial Region

Branch ___
Davao City

THE PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO.________________

Complainant,
FOR: ESTAFA
-versus-

NAME OF ACCUSED
Accused.
X---------------------------X

MOTION TO REDUCE BAIL

UNTO THIS HONORABLE COURT, Accused, through counsel, most

respectfully aver:

1. That Accused is presently detained at Police Station, ________ City,

pending the hearing of this case, and that this case has been raffled
to this sala;

2. That the Resolution of the Honorable Office of the City Prosecutor

has fixed the bail of the accused at P20,000.00;

3. That the recommended bail for the offense of Estafa is P6,000.00, in

accordance with the 2000 Bail Bond Guide of the Department of
Justice National Prosecution Service;

4. That accused is not affluent in life, being a mere employee with

minimum wage;

5. That the bail recommended is tantamount to the denial of bail.

Where the right to bail exists, it should not be rendered nugatory by
requiring a sum that is so excessive.

6. That accused is asking for the reduction of bail to P 10,000, which

amount the accused can raise;

7. That accused is a good member of the community, and a resident of

Davao City, and the probability of flight is nil;
 8. That accused has not been previously convicted of any crime and
have no pending case in any judicial or quasi-judicial body in the
Philippines.

9. That accused will undertake to be present when this case is called in

Court.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed that the

Honorable Court will allow accused to post bail in the amount of P 10,000.00 for
his provisional liberty during the pendency of this case.

Davao City, Philippines, _____________.

By:

ATTY. ____________________________
Counsel for the accused

NOTICE OF HEARING

THE CITY PROSECUTOR

City Prosecution Office
________________________
________________________

THE CLERK OF COURT

COURT
BRANCH __
CITY

Greetings:

Please submit the foregoing Motion for the consideration and approval of this Honorable Office on
________________ at __________o’clock in the morning or as soon as this may be heard.

ATTY. ______________________