Republic of the Philippines

REGIONAL TRIAL COURT

Fifth Judicial Region
BRANCH 51
Sorsogon City

PEOPLE OF THE PHILIPPINES,

CRIMINAL CASE NO. 2020-
Plaintiff 11403C
,

- versus -

MOISES A. DUGAN, JR.

Accused
.
x----------------------------
-x

MOTION TO REDUCE BAIL PURSUANT TO

ADMINISTRATIVE CIRCULAR NO. 38-2020
ACCUSED, assisted by the Public Attorney’s Office and to the Honorable Court,
respectfully states:

1. That the accused has been charged with the violation of section 10 (a) of RA
7610;

2. That the recommended bail for the said offense is Eighty Thousand Pesos (Php.
80,000.00);

3. That pursuant to Administrative Circular No. 38-2020, the amount of bail now
may be significantly reduced, as it states with particularity, that –

“2. For those charged with a crime punishable with the maximum
period of prision mayor or six (6) years and one (1) day to twelve (12)
years, the bail shall be computed by getting the medium period
multiplied by Two Thousand Pesos (P2,000.00) for every year of
imprisonment;”

4. That in this case, the imposable penalty is prision mayor minimum;

5. Following the computation above, the medium period at most of prision mayor is
10 years. And if multiplied by Two Thousand Pesos (P2,000.00) for every year,
that will result to TWENTY THOUSAND PESOS (P20,000.00);

6. That the accused is a poor fellow of very limited means such that it is impossible
for him to pay the full amount of his bond and is, therefore, constrained to request
for a reduction of the amount of bail pursuant to the above circular;
 7. That it would be advantageous to everyone if he be given temporary liberty
thereby allowing him to continue with his life as a productive member of the
society in line of the intent of the Supreme Court to decongest jail facilities;

8. As such, accused appeals to the mercy and compassion of this Honorable Court
and respectfully requests that his bail be reduced to TWENTY THOUSAND
PESOS (P 20,000.00) subject to the sound discretion of the Honorable Court;

9. That this motion for reduction of bail is being filed without prejudice to any other
remedies which may be available to the accused.

WHEREFORE, accused respectfully prays that his bail be reduced on the basis of
above proposal.

Other relief just and equitable are likewise prayed for.

July 2, 2020, Sorsogon City.

Department of Justice
PUBLIC ATTORNEY’S OFFICE
Counsel for the Accused
Sorsogon City District office
Hall of Justice Building, Sorsogon City

By:

ATTY. CHRISTIAN R. SANTONIA

Public Attorney II
Roll No. 70011
IBP O.R. No. 102562, 01-03-2020
MCLE Compliance No. VI – 0005934

NOTICE OF HEARING
LORNA T. PURA-VERZOSA
OIC Branch Clerk of Court
RTC Branch 51
Sorsogon City

Greetings!

Please submit the foregoing Motion for the consideration and approval of
the Honorable Court in its most convenient time.

CHRISTIAN R. SANTONIA
Copy furnished:
CITY PROSECUTOR’S OFFICE
Bulwagan ng Katarungan
Sorsogon City