Republic of the Philippines

Second Judicial Region

REGIONAL TRIAL COURT
OFFICE OF THE EXECUTIVE JUDGE
City of Ilagan, Isabela

THE PEOPLE OF THE

PHILIPPINES,
Plaintiff,
Crim. Case No.

-versus-
For: ILLEGAL
Accused. POSSESSION OF
FIREARM AND
AMMUNITIONS
x-----------------------------------------x
MOTION TO POST BAIL
The accused, Jby the undersigned counsel, and unto this Honorable
Court, most respectfully states:

1. That on May 2, 2023, the Office of the Provincial Prosecutor of

Isabela filed an Information against the accused for the crime of Violation of
Republic Act No. 10591, the recommended bail for his provisional liberty is
one hundred thousand Pesos (Php 100,000.00);

2. That this case was raffled before the Regional Trial Court Branch
22 and the accused is praying that he be allowed to post bail for his
provisional liberty, pursuant to his constitutional right to bail and pursuant to
the provisions of Section 4 of Rule 114 of the Revised Rules on Criminal
Procedure, which states:

Section 4. Bail, a matter of right; exception. — All persons in

custody shall be admitted to bail as a matter of right, with
sufficient sureties, or released on recognizance as prescribed by
law or this Rule (a) before or after conviction by the
Metropolitan Trial Court, Municipal Trial Court, Municipal
Trial Court in Cities, or Municipal Circuit Trial Court, and (b)
before conviction by the Regional Trial Court of an offense not
punishable by death, reclusion perpetua, or life imprisonment.

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 3. The accused is supposed to post bail before the Regional Trial Court
Branch 22, however, the Honorable Judge Jennifer S. Loveria is still awaiting
for the assumption of her judicial functions. Attached herein is the
Certification issued by the Clerk of Court od RTC Branch 22; and

4. That in the event the Honorable Court will grant this

aforementioned Motion, the accused undertakes to appear before the
Regional Trial Court Branch 17 whenever he is thereby required to do so.

PRAYER

WHEREFORE it is most respectfully prayed of the Honorable Court

that an order be issued granting the foregoing motion and for the accused to
be allowed to post bail in the amount of One Hundred Thousand Pesos (Php
100,000.00) as recommended.

Other just and equitable reliefs are likewise prayed for.

City of Ilagan, Isabela, 3rd May 2023.

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