Republic of the Philippines

REGIONAL TRIAL COURT

7TH Judicial Region
Branch XX, Cebu City

PEOPLE OF THE PHILIPPINES,

Plaintiff,

-vs- CRIM.CASE N0. XX

For: Viol.of Sec.5,Art.II, R.A. 9165

CRIM.CASE N0. XX
For: Viol.of Sec.11,Art.II,R.A. 9165,

XXX,

Accused.
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MOTION TO FIX AND POST BAIL

Accused, assisted by the XX, unto this Honorable Court most respectfully
states:

1. Sometime in July 2021, he pleaded guilty to a lesser offense (Violation

of Sec.12, Art.II, R.A 9165) for both cases and sentenced to serve an
indeterminate imprisonment of from six (6) months and one day as
minimum, to one year, as maximum, and a fine of Php10,000.00, also
for each case;
2. He filed an Application for Probation;
3. He is a PDL of XXX Jail-Male Dormitory, Cebu City,
4. The said facility has been affected by the COVID-19 pandemic, hence,
he is apprehensive that he might get sick while in the said facility;
5. Thus, he beg the kind indulgence of this Honorable Court, for
humanitarian reasons , that he be allowed to post bail for his
provisional liberty pending the resolution of his application for
probation as well as his compliance with the required Dangerous
Drugs Examination result;
6. This Motion is being filed in good faith and not intended to delay the
proceedings of this Honorable Court.

PRAYER

WHEREFORE, it is most respectfully prayed of this Honorable Court, for

humanitarian reasons, that an amount be fixed for the bail of XXXX and to allow him
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to post bail for his provisional liberty pending the resolution of his application for
probation as well as his compliance with the required Dangerous Drugs Examination
result or recommendation.

Other just and proper remedies are likewise prayed for.

Respectfully submitted. XXX. XXX City, Philippines.

XXX
(Counsel for this purpose only)
XXX

By:

Sgd
XXX
Public Attorney II
Roll N0. XXX
IBP AR #XXX/ XXX City Chapter
MCLE Compliance N0. XXX valid until :April 14, 2022

XXXX
Branch Clerk of Court
Regional Trial Court, Branch XX
XXX

Please submit the foregoing Motion for the consideration of the Honorable
Court as soon as possible sans appearance of counsels. Thank You.

XXX

Copy furnished
XXX
Cebu City Prosecutor’s Office
XXX

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EXPLANATION: Copies of the foregoing Motion were being served and filed thru
email pursuant to pertinent provisions of AC 33-2020 and OCA Circular N0. 89-2020;
also due to distance and lack of personnel to effect personal service and filing.

XXX

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