Republic of the Philippines

REGIONAL TRIAL COURT

11th Judicial Region
Branch 28
Lianga, Surigao del Sur

PEOPLE OF THE PHILIPPINES CRIM. CASE NOS. 21-4019

Plaintiff, & 21-4020
For:
ACT OF LASCIVIOUSNESS
-vs- (RPC ART. 336) IN
RELATION TO R.A. 7610

NEMENCIO POCON,
Accused.
X----------------------/

MOTION FOR REDUCTION OF BAIL

Accused, alleges:

1. That warrant of arrest has already been issued

before the Honorable Court against the accused for
the above cases ;

2. That the bail bond are fixed at Eighty Thousand

Pesos (P80,000.00) each case, for his temporary
liberty ;

3. That the abovementioned accused is jobless and had

no property registered in his name or registered in
the name of his relatives to be utilized as property
bond ;

4. That the accused’ friends and relatives offered to

lend the amount of P80,000.00 only to answer the
bail bond ;
 5. That due to extreme financial hardship, his family
can no longer secure the balance in the sum amount
of P80,000.00 hence, this motion ;

6. That after diligent efforts to produce more cash to

raise the amount fixed for their bail, the said
accused cannot anymore produce the difference of
P80,000.00 thus, this motion because the accused is
ready to put up the cash for his bail in the amount
of P40,000.00 in each cases ;

7. That this motion is filed in good faith.

WHEREFORE, it is respectfully prayed of this Honorable

Court that the bail required for the accused’ temporary
liberty be reduced to P40,000.00 for each case instead of the
P80,000.00 in the interest of substantial justice.

RESPECTFULLY SUBMITTED.

San Francisco, (for Lianga, Surigao del Sur) Agusan del

Sur this 18th day of November 2021.

ALVIZO and MONTILLA LAW OFFICES

2/F Tiu Bldg. Obedoza St., Brgy. 2
San Francisco, Agusan del Sur

By:

LEON O. MONTILLA, JR.

IBP Lifetime No. 03110
PTR No. 9052420 on 1-8-21
at Agusan del Sur
Roll No. 44691
MCLE Compliance No. VI - 0003236
October 2, 2017 - Pasig City
(Until April 2022)
Email: lemon_law@yahoo.com
 NOTICE

OFFICE OF THE PROVINCIAL PROSECUTOR

Lianga, Surigao del Sur

THE CLERK OF COURT

RTC – Branch 28
Lianga, Surigao del Sur

GREETINGS : Please submit the foregoing motion to the

Honorable Court on November 23, 2021 at 2:00 o’clock in the
afternoon, for its kind consideration. Thank you very much.

LEON O. MONTILLA, JR.