Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
BRANCH 18
Digos City, Davao del Sur

PEOPLE OF THE PHILIPPINES, CRIM. CASE NOS. 06 (02) &

Plaintiff, 07 (02)

- versus - FOR:MURDER & FRUSTRATED

MURDER

REY MOLEJON,
Accused.
X - - - - - - - - - - - - - - - - -- - -- - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - /

APPEARANCE AS COUNSEL WITH MOTION TO RESOLVE

PETITION FOR BAIL AND MOTION TO SET THE HEARING
EARLIER PREFERABLY ON DECEMBER 3, 2012

Comes now the ACCUSED, through the undersigned counsel and unto this
Honorable Court, most respectfully avers:

ARGUMENTS

1. Appearance as Counsel for the Accused

That the legal services of the undersigned was engaged by the herein accused
relative to this case;

That the undersigned Counsel enters his appearance as counsel for the accused
in this case. Thus, he prays that he be serve with all notices, writs and orders from this
Honorable court at his given address below;

2. Motion to Resolve Petition for Bail

That accused REY MOLEJON is under detention;

That he filed a Petition for Bail before this Honorable Court asking for his
temporary liberty pending the resolution of this case;

That until now, the said petition for bail was not yet acted upon by this Honorable
Court;
Page 2…./
Motion…/
x----------------/

That the evidence of the prosecution to prove the guilt of the accused is not
strong. Thus, the herein accused is entitled to bail as a matter of discretion;

3. MOTION TO SET THE CASE TO AN EARLIER DATE

That an Order dated November 8, 2012 was issued by this Honorable Court
setting the hearing of this case on February 7, 2013 at 8:30 in the morning;

That the undersigned counsel moves for the resetting of the scheduled hearing of
the above entitled case to an earlier date preferably on December 3, 2012 for the
reason that the scheduled date set by this Honorable Court on February 7, 2012 is yet
very far considering that the herein accused is under preventive imprisonment;

PRAYER

WHEREFORE, in view of the foregoing, ACCUSED, through the undersigned

counsel and unto this Honorable Court, most respectfully prays that his appearance be
entered on record and that his pending resolution for bail be immediately resolve.
Accused further prays that the hearing of this case be set to an earlier date preferably
on December 3, 2012.

Any other just and equitable reliefs available in the premises are likewise prayed
for;

Digos City, Philippines, this 22nd day of November, 2012.

 ATTY. LUCIANO G. CAMEROS, CPA
Counsel for the Accused
MCLE Compliance Cert. No. III, 0011279, Aug. 21, 2008
MCLE Compliance Cert. No. IV, 0000673, Nov. 4, 2010
PTR No. 3525808/01-03-2011/Hagonoy, Davao del Sur
IBP O.R.No. 723578/ 12-01-2010/ Digos City
TIN No. 143-089-251/ Roll No. 41499
Corner Magsaysay & Lapulapu Sts. Digos City
Telephone/Fax No. (082)-553-5885
Cellular Phone No. 0910-973-6588
Email address- atty_cameros @yahoo.com

NOTICE

The Clerk of Court

RTC-Branch 18
Digos City, Davao del Sur

Atty. Randolf C. Pensoy

PAO, Digos City
Page three…./
Motion…./
Abellera, et al. vs. Abellera, et. al…./
x----------------------------------------------------/

Sir/Madam:

Please submit the foregoing motion for the kind consideration and approval of
this Honorable Court immediately upon receipt hereof without further arguments from
counsel.

ATTY. LUCIANO G. CAMEROS, CPA

Copy furnished:

Atty. Randolf C. Pensoy

PAO, Digos City