REPUBLIC OF THE PHILIPPINES

THIRD JUDICIAL REGION

MUNICIPAL TRIAL COURT of Dingalan
Municipality of Dingalan
Province of Aurora

PEOPLE OF THE PHILIPPINES,

Complainant,

- versus - CRIMINAL CASE

NO.899

FOR: Qualified Trespass to Dwelling

under Art. 280 of the RPC

Erick Lachica
Accused,
x - - - - - - - - - - - - - - -- - - - - - - - x

MOTION TO POST AND REDUCE BAIL

The accused, ERICK LACHICA, through the undersigned

counsel in the above-entitled case, and to this Honorable Court
respectfully states that:

1. The accused, ERICK LACHICA, is charged for Qualified

Trespass to Dwelling now pending before this Honorable Court
with Criminal Case No. 899;

2. That the recommended bail for his provisional liberty is in the

amount of THIRTY THOUSAND PESOS (Php30,000.00);

3. That the accused, considering that he is at this time suffering

from financial constraints, and he is not affluent in life and
currently has unstable source of income due to the pandemic
can only produce the amount of FIFTEEN THOUSAND PESOS
(Php15,000.00) CASH;

4. That the accused needs his temporary liberty in order for him
to gather all the necessary evidence for his proper defense from
 this baseless accusation which he cannot do if inside the prison;

5. That the accused together with his family are permanent

residents of this Province of Aurora, particularly at Barangay
Aplaya, Municipality of Dingalan, and therefore the possibility
for hims to jump bail is too nil;

6. That the accused promises to attend all scheduled hearing in

the above-entitled case and obey all the processes of this
Honorable Court.

PRAYER

WHEREFORE, premises considered and in view of the

foregoing, it is respectfully prayed to the Honorable Court that the
recommended bond of Php30, 000.00 will be reduced to Php15,
000.00 CASH.

Other relief and remedies just and equitable under the premises
are likewise prayed for.

Dingalan, Aurora, Philippines, this 24th day of August 2022.

ATTY. QUEEN JANE TADEJA ALDAVE

Counsel for the accused
PTR NO.: 6411382, May 19, 2022 Dingalan, Aurora
IBP OR NO.: 189575, May 4, 2022, Nueva Ecija
Roll Number: 76089, May 4, 2022
Admitted to the Philippine Bar on May 4, 2022
queenjanetadeja.aldave2121@gmail.com/09566971432
Davil-Davilan, Dingalan, Aurora
 NOTICE AND REQUEST

THE CLERK OF COURT

MTC, Dingalan, Aurora

Greetings!

Please submit the foregoing motion to the Honorable Court

immediately upon receipt thereof for its consideration and approval
without further arguments.

ATTY. QUEEN JANE TADEJA ALDAVE

Copy Furnished:
OFFICE OF THE PROSECUTOR
MTC, Dingalan, Aurora