Republic of the Philippines

Regional Trial Court

FIRST JUDICIAL REGION
Branch 63
La Trinidad, Benguet

People of the Philippines

Complainant, Crim. Case No. 17-CR-12083

-versus- FOR:

ESTAFA
MARK ANDREW B. DIRECTO,
Accused.

Voluntary Surrender with

Motion to Reduce Bail
The Accused, MARK ANDREW DIRECTO, unto this Honorable Court,
most respectfully and voluntarily surrenders to the Honorable Court, and moves for
the Reduction of Bail, in the instant case, thus allege:

1. That the present case was raffled to the Honorable Court;

2. That the bail recommended by the Honorable Public Prosecutor for the
provisional liberty of the Accused, is in the amount of TWENTY TWO
THOUSAND PESOS (PhP22,000.00);

3. That the Accused has no regular employment, at present, and has a

family to provide for, and therefore has no sufficient means, to produce
the aforementioned amount;

4. That it was through his relatives that he was able to produce only the
amount of TWELVE THOUSAND PESOS (PhP12,000.00), by
borrowing from the said persons;

5. That the Accused professes his innocence and undertakes to attend every
hearing and comply with all the conditions, set by the Honorable Court,
for his provisional liberty;

6. That this motion is filed solely for the above-reason and not intended to
delay the prompt disposition of this case.

PRAYER

WHEREFORE, premises considered, it is respectfully prayed of this

Honorable Court to:

1. Note the Voluntary Surrender of the Accused and Lift the Warrant of Arrest;

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 2. To grant the foregoing Motion, and reduce the recommended amount of bail
from TWENTY TWO THOUSAND PESOS (PhP22,000.00) to
TWELVE THOUSAND PESOS (PhP12,000.00);

3. Subject to the payment of the said amount, to order the provisional release of
the Accused.

Other reliefs which are just and equitable under the premises are likewise
prayed for.

RESPECTFULLY SUBMITTED, this 5TH day of September 2017, at

Baguio City, Philippines.

MARK ANDREW DIRECTO

Notice

THE BRANCH CLERK OF COURT

Regional Trial Court
Branch 63
Justice Hall, La Trinidad, Benguet

Please submit the foregoing motion for the consideration and approval of
this Honorable Court upon receipt hereof.

THE HONORABLE PUBLIC PROSECUTOR

Regional Trial Court
Branch 63
Justice Hall, La Trinidad, Benguet

Please take notice that the foregoing motion has been submitted for the
consideration and approval of this Honorable Court upon receipt hereof.

JOSHUA P. PABLITO

COPY FURNISHED:

THE HONORABLE PUBLIC PROSECUTOR

Justice Hall, La Trinidad, Benguet

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