Republic of the Philippines

REGIONAL TRIAL COURT

Fourth Judicial Region
BRANCH 15
Lucena City

THE PEOPLE OF THE PHILIPPINES,

Plaintiff,

-versus- Crim. Case No. 2019-1293

For: Slight Physical Injuries

MA. YVETTE FLORES y AGUSTIN,

Accused.
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MOTION TO FIX AND REDUCE BAIL BOND

ACCUSED, by the undersigned counsel de officio from the

Public Attorney’s Office and unto this Honorable Court, most
respectfully alleges and moves:

1. Accused has been charged for the above-captioned

offense and that the bail recommended for her provisional release
has been set at Three Thousand Pesos (PHP 3,000.00).

2. Accused has very limited means as of the moment, as

such, it would be difficult for her to pay the full amount recommended
for bail and is therefore constrained to seek and request for the
amount of bail to be fixed and reduced to One Thousand Five
Hundred Pesos (PHP 1,500.00).

3. On the foregoing premise, accused appeals to the mercy

and compassion of this Honorable Court and respectfully requests
that her bail be fixed at a reduced amount of One Thousand Five
Hundred Pesos (PHP 1,500.00);

4. That this motion to fix and reduce the amount of the bail
bond is being filed without prejudice to any other remedy which may
be available to the accused and is not intended to delay the
proceedings of this Honorable Court.
 PRAYER

WHEREFORE, it is most respectfully prayed for by the accused

from this Honorable Court that his bail be fixed at a reduced amount
of One Thousand Five Hundred Pesos (PHP 1,500.00).

Other reliefs just and equitable are likewise prayed for.

City of Lucena, Quezon Province, 16 August 2019.

Respectfully submitted:

DEPARTMENT OF JUSTICE
PUBLIC ATTORNEY’S OFFICE
Lucena City District
3/F Midtown Pavilion Building
Quezon Avenue cor. Governor Guinto
Street, Lucena City

By:

FRANCES DYAN T. LIM

Public Attorney II
Roll of Attorney’s No. 63546
IBP Life Member Roll No. 015685
MCLE Compliance No. VI-0007393

Copy furnished:

Prosecutor Caress L. Oleriana

Office of the City Prosecutor
Lucena City Government Complex, Diversion Road,
Lucena City, Quezon

NOTICE

Mr. Joseph Jennel M. Malelang

Officer-in-Charge
Family Court RTC Branch 15, Lucena City

G R E E T I N G S:
 Please submit the foregoing Motion for the kind and prompt
consideration of this Honorable Court immediately upon receipt
hereof.

Thank you very much.

Atty. FRANCES DYAN T. LIM

EXPLANATION

Due to time and distance constraints to personally serve this

Motion, the same was effected via registered mail pursuant to Section
11, Rule 13 of the Revised Rules of Court.

Atty. FRANCES DYAN T. LIM