Republic of the Philippines

SUPREME COURT
10th Judicial Region
MUNICIPAL CIRCUIT TRIAL COURT
MAGALLANES-REMEDIOS T. ROMUALDEZ-LAS NIEVES
Hall of Justice, Brgy. Marcos, Magallanes
Province of Agusan Del Norte

PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. __________

Plaintiff,
- versus –
For: Violation of P.D. 1602
ELDEFONSO PADILLA MIOLE and
LOLY LICAYAN REOJA
Accused.
x------------------------x

MOTION TO REDUCE BAIL BOND

ACCUSED Eldefonso Miole and Loly Reoja, thru undersigned counsel of the Public
Attorney’s Office, unto this Honorable Court, most respectfully avers:

1. The accused has been charged with Violation of Sec. 1 (a) [1] of P.D. 1602 which carries a
penalty of prison correccional in its medium period of a fine ranging from one thousand to
six thousand pesos;

2. That in response to the coronavirus threat within Philippine jails, the Supreme Court issued
SC Admin. Circular 38-2020, giving the courts discretion to lower the amount of bail bond
based on the penalties of corresponding offenses;

3. That SC Admin Circular 38-2020 provides:

“3. For those charged with a crime punishable with the maximum period
of prision correccional or six (6) months and one (1) day to six (6) years, the
bail shall be computed by getting the medium period multiplied by One
Thousand Pesos (P1,000.00) for every year of imprisonment;”

4. That prision correccional as a penalty under the RPC can be divided as follows:

PRISION CORRECCIONAL – 6 years and 1 day to 12 years

PRISION CORRECCIONAL MINIMUM - 6 months and 1 day to 2 years and 4

months.
PRISION CORRECCIONAL MEDIUM - 2 years, 4 months and 1 day to 4 years
PRISION CORRECCIONAL MAXIMUM - 4 years, 2 months and 1 day to 6 years

5. Thus, under the applicable Supreme Court Circular, the accused requests that the
Honorable Court allow them to put up the bond of 4 years x P1,000.00 = FOUR
THOUSAND PESOS (P4, 000.00) EACH;
6. That accused has a valid defense, and thus the probability of the accused to abscond is
remote.

PRAYER

WHEREFORE, accused respectfully prays that their bail be set at Four Thousand Pesos
(P4,000.00) EACH based on SC Admin. Circular 38-2020.

Other reliefs just and equitable are likewise prayed for.

Respectfully Submitted. Cabadbaran City for Magallanes, Agusan Del Norte, Philippines.
February 2, 2022.

Public Attorney’s Office

Cabadbaran District Office
Counsel for the Accused-Movant

By:

JO EDWARD F. YECYEC
Public Attorney II

With Conformity:

Remarks: ___________________

HON. DANNY C. SERRANO

In his Capacity as Provincial Prosecutor
Office of the Provincial Prosecutor of Agusan Del Norte
Libertad, Butuan City

NOTICE OF HEARING

Edith P. Brigoli
The Clerk of Court
MCTC-Magallanes-RTR-Las Nieves

Handling State Prosecutor

Office of the Provincial Prosecutor

Greetings!

Please take notice that we are submitting the foregoing motion to the Honorable
Court for its kind consideration and approval immediately upon receipt hereof.

ATTY. JO EDWARD F. YECYEC

Copy furnished: [by hand]

PROS. DANNY C. SERRANO

Office of the Provincial Prosecutor
Hall of Justice, Libertad
Butuan City