Republic of the Philippines

REGIONAL TRIAL COURT

8th Judicial Region
Branch 32
Calbayog City

PEOPLE OF THE PHILIPPINES, Criminal Case No. 8002

Complainant,

- Versus –

ROMEO EVARDONE JR. @ “Jojo”, For: ESTAFA with Abuse of

Accused. Confidence thru Misappropriation
x------------------------------------------x & Conversion (Under Art. 315,
Par. 1(b), RPC)

MOTION TO REDUCE BAIL

ACCUSED, thru the undersigned counsel, and unto this HONORABLE COURT,
respectfully manifests:

1. That an information for Estafa was filed against him and for his temporary
liberty, the bail bond recommended is P40,000.00;

2. That the accused is a not affluent in life and of very limited means such that
it is impossible for him to pay the full amount of his bond and is therefore
constrained to request for a reduction of the amount of bail;

3. That it would be advantageous to everyone if he be given temporary liberty

thereby allowing him to continue with his gainful employment and as head
of the family with five(5) dependents;

4. That the accused would like to avail of his constitutional right to bail, but
since he could not raise the required amount due to his limited financial
resources, the accused earnestly appeals to the mercy and compassion of
this HONORABLE COURT that the bond be reduced to P20,000.00;

5. That the accused is willing to face the instant case filed against him and has
no intention of jumping bail;

WHEREFORE, it is most respectfully prayed before this HONORABLE COURT that

the bail bond fixed in the amount of P40,000.00 be reduced to P20,000.00 and that he
be allowed to deposit the same in court and be temporarily released by virtue of the
said bond pending trial of this case.

RESPECTFULLY SUBMITTED.

Calbayog City, Samar, July 06, 2017

ATTY. JEFFREY R. BERNATE

Counsel for the Accused
Bernate Cmpd., P-1, Brgy. Capoocan, Calbayog City, Samar
Roll No. 67531 / May 24, 2017
IBP No. 005158 / May 24, 2017 / Samar
PTR No. 6908378 / May 29, 2017/ Calbayog City
MCLE Compliance: NEW
Email Address: jrbernate1234@gmail.com

NOTICE OF HEARING

THE BRANCH CLERK OF COURT

Regional Trial Court - Branch 32
Calbayog City

Greetings!

Please submit the foregoing Motion for the consideration and approval of the
HONORABLE COURT as soon as this may be heard.

Thank you.

ATTY. JEFFREY R. BERNATE

Copy furnished by personal service:

Office of the City Prosecutor

Calbayog City