Republic of the Philippines

REGIONAL TRIAL COURT

11th
Judicial Region
Branch 23
Davao City

THE PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO.2323

Complainant, FOR: ESTAFA

-versus-

RAMONY RAMONA
Accused.
X-------------------------
--X

MOTION TO REDUCE BAIL

UNTO THIS HONORABLE COURT, Accused, through counsel, most

respectfully aver:

1. That Accused is presently detained at Talomo Police Station,

Davao 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, March 12, 2020.

By:

ATTY. PAULO JOSE S. VILLARIN

Roll of Attorneys No. 696969
PTR No. 69669, 4-24-20, Davao City
IBP No. 5559, 4-24-20, Davao City
MCLE Compliance No. VII-0220293; 4-19-19
Valid until April 14, 2022
Ecoland, Davao City

NOTICE OF HEARING

CITY PROSECUTION’S OFFICE

_____________________

CLERK OF COURT
Regional Trial Court
Branch 23
Davao City

MA’AM:

Greetings!
 Please take notice that on March 12, 2020 at 8:30 o’clock in the
morning or upon the approval of the Honorable Court the instant Petition
shall be heard.

Thank you.

ATTY. PAULO JOSE S. VILLARIN