Republic of the Philippines

REGIONAL TRIAL COURT

___th Judicial Region
Branch __, ____ City

PEOPLE OF THE PHILIPPINES, CRIMINAL CASE NO.

NPS DOCKET NO.

- versus -
FOR: VIOLATION OF SECTION
11 in RELATION TO SECTION 25
JUAN DELA CRUZ,
of RA 9165 as Amended by RA No.
Accused. 10640
x------------------------- -x

MOTION FOR RECONSIDERATION

COMES NOW, the undersigned counsel, and unto this Honorable Court,
most respectfully states that:

1. On March 19, 1998, the Accused filed its Petition for Bail with
Motion to Reduce Bail. A copy of which is hereto attached and marked as Annex
“1”;

2. Upon inquiry over the phone to RTC Branch 9, the staff of the
undersigned counsel was informed that there would be no hearing for that week
and that hearings will start this week or on March 10, 1998;

3. Thus, the undersigned respectfully requested in the Notice of

Hearing that the Motion be heard on March 10, 1998 or any date thereafter subject
to the availability of the Honorable Court’s calendar;

4. In the afternoon of March 22, 1998 (Friday), the undersigned

counsel inquired from this Honorable Court to confirm the schedule of the
hearing. Unfortunately, the undersigned counsel was informed that the
aforementioned Petition for Bail with Motion to Reduce Bail already was set for
hearing that day but the undersigned counsel failed to appear;

5. The undersigned counsel was not able to attend the aforementioned

hearing because neither the undersigned counsel nor any of his staff receive any
communication that the same was set for hearing that day contrary to the earlier
information he received that court hearings will resume this week. The
undersigned counsel has no intention whatsoever to disregard the scheduled
hearing and waste the precious time of this Honorable Court;

6. Thus, in view of the foregoing, the undersigned respectfully

beseeches the compassion and understanding of the Honorable Court to reconsider
the denial of the Motion to Reduce Bail on humanitarian considerations in order
for the Accused to enjoy her right to post bail despite her family’s dire financial
constraints and spare her and her family from the tormenting anxiety on the
thought that the Accused may be infected with Spanish Flu while under detention.

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 PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of this

Honorable Court to reconsider the denial of the subject Petition for Bail with
Motion to Reduce Bail filed by Accused and grant the Accused’s prayer for the
reduction of the recommended bail.

Other reliefs just and equitable are likewise prayed for.

Davao City, Philippines, March 26, 1998.

Assisted by:

LAWYER

NOTICE OF HEARING

THE CLERK OF COURT

BRANCH __, RTC of _____ City

THE CITY PROSECUTOR

City Prosecution Office
Hall of Justice, _____ City

Greetings:

Please submit the foregoing Motion for Reconsideration for the consideration and
approval of this Honorable Court and/or set the same for hearing on May 29, 2020 at
2:00 o’clock in the afternoon or as soon as this may be heard subject to the availability
of this Honorable Court’s calendar.

LAWYER

Copy furnished:

City Prosecution Office Received by: _________________________

______ City Date: ______________________________

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