Republic of the Philippines

REGIONAL TRIAL COURT

First Judicial Region
Branch 8
La Trinidad, Benguet

THE PEOPLE OF THE PHILIPPINES,

Plaintiff, CRIM CASE NO. 123-CR-45678

For:
ESTAFA UNDER ART. 315 PAR. 2(A) OF
THE REVISED PENAL CODE IN
- versus – RELATION TO SEC. 6 OF RA 10175

ABC

DEF

Accused

x----------------------x

VOLUNTARY SURRENDER WITH MOTION FOR REDUCTION

OF BAIL

ACCUSED, assisted by the undersigned counsel, unto this Honorable Court, most

respectfully alleges that:

1. The accused has been charged with ESTAFA UNDER ART. 315 PAR. 2(A) OF
THE REVISED PENAL CODE IN RELATION TO SEC. 6 OF RA 10175;

2. Consequently, warrant of arrest was issued against accused and the bail for
their provisional liberty has been set at P18, 000.00 each with a total of P 36,
000.00 for the said case;

3. Both accused desire to post the required bail but due to financial constraints
considering that ABC is only driving a taxi under a boundary system and his live-
in partner, DEF is jobless and have five children, they can only raise the amount
of P18, 000.00 for both accused for the above-mentioned case with the help of
their friends and family;

4. To attest to their financial difficulty, a Certificate of Indigency is attached

herewith for the kind consideration of the Honorable Court; and

5. The possibility of jumping bail is very remote considering both accused are
permanent residents of _______________________.
WHEREFORE, in view of the foregoing, it is most respectfully prayed to this Honorable
Court to take note of the voluntary surrender of both Accused and be allowed to post
their bail bond for the above-mentioned case at a reduced CASH BOND in the total
amount of Eighteen Thousand Pesos (P18, 000.00) for both accused.

Other reliefs just and equitable in the premises are likewise sought.

La Trinidad, Benguet. October 2022.

HIJ
Counsel for the Accused
Roll No.
PTR No.
IBP No.
MCLE Compliance (Newly Admitted) as per Governing Board Order 1-2008,
04 July 2008)
Cp number
Email
Office address

NOTICE

The Honorable Branch Clerk of Court

RTC Branch 8,
Justice Hill, La Trinidad, Benguet

Madam:

Please submit the foregoing motion for the kind consideration of this Honorable Court.

ATTY. HIJ

Copy Furnished:

OFFICE OF THE PROV’L PROSECUTOR

Justice Hill, La Trinidad, Benguet By: personal delivery