REPUBLIC OF THE PHILIPPINES

MUNICIPAL TRIAL COURT OF ROSARIO

FOURTH JUDICIAL REGION
PROVINCE OF BATANGAS

PEOPLE OF THE PHILIPPINES, Criminal Case No:

Plaintiff,

-versus- -for-

_____________________________, GRAVE THREATS

Accused.
x---------------------------------------------x

MOTION FOR RECONSIDERATION

Comes now, the Accused, through the undersigned counsel, and unto
this Honorable Court respectfully states:

That, the case filed against the Accused was DISMISSED in the Order
of this Honorable Court, which states;

“xxx The accused thru counsel, Atty. _______________ confirmed the

Manifestation and joined the prosecution’s Motion for the dismissal of
the case as it would be impossible to prove the guilt of the accused
beyond reasonable doubt without the cooperation of the private
complainant. xxx”

That, the Accused, through the undersigned counsel, filed a Motion to

Release Cash Bond unto this Honorable Court, that it received on September
4, 2017, which sought the release of the Cash Bond posted by the
Bondsman, ___________, for the provisional liberty of the Accused in this
case, for the amount of Two Thousand Pesos (P 2000.00), under the Official
Receipt No. ______, a certified true copy of which is attached herein as
Annex “1”;

That, in the Order of this Honorable Court dated September 7, 2017,

the motion to release cash bond filed by the accused was denied by the
Honorable Court, to wit;
 “xxx The records are bereft of any document /s showing that the
accused posted in this Court cashbond for his provisional liberty

In the Order of March 10, 2017, the Court had noted the manifestation
of the Public Prosecutor that the accused posted bail at the Regional
Trial Court, Branch 87, Rosario, Batangas.

No records of bail documents however had been forwarded to this

Court. xxx”

That, it was found out that the bail documents for the provisional liberty
of herein Accused are in the possession of the Office of the Provincial
Prosecutor, Rosario, Batangas, and the only bail document in the
possession of the Regional Trial Court, Branch 87, Rosario, Batangas, is the
Official Receipt paid for the cash bond of the Accused, as shown in a
transmittal letter issued by the Regional Trial Court, Branch 87 Clerk of
Court, a copy of which is herein attached as Annex “2”;

That, the original of all bond documents are in the possession of the
Office of the Provincial Prosecutor, copy of each are attached hereto as:

Annex “3” - Order of the Regional Trial Court, Branch 87, Rosario,
Batangas, dated February 21, 2017;
Annex “4” - Information Sheet;
Annex “5” - Inquest Resolution, dated January 9, 2017;
Annex “6” - Undertaking, subscriber and sworn to on February 21,
2017;
Annex “7” - copy of Community Tax Certificate of ___________;
Annex “8” - Certificate of Detention, issued on January 8, 2017;
Annex “9” - Barangay Clearance, issued on February 21, 2017, at
Barangay Putingkahoy, Rosario, Batangas;
Annex “10” -set of pictures of _____________;

PRAYER
WHEREFORE, premises considered, it is most respectfully prayed of
this Honorable Court that the Order dated September 7, 2017be SET ASIDE
AND RECONSIDERED, and that the BAIL BOND OF THE ACCUSED BE
RELEASED to the bondsman.

Other relief just and equitable in the foregoing premises are likewise
prayed for.
Rosario, Batangas, January 15, 2016.