Republic of the Philippines

National Capital Judicial Region

METROPOLITAN TRIAL COURT
Quezon City
Branch ___

PEOPLE OF THE PHILIPPINES,

Plaintiff,

- versus - Crim. Case No. _____________

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

MOTION TO REDUCE BAIL

Accused, through counsel, by way of a special appearance, respectfully

alleges, that:

1. Accused/Movant is charged before this Honorable Court for the above-

mentioned criminal case for which the recommended bail for his temporary
liberty is Ten Thousand Pesos (Php10,000.00);

2. He is presently detained at Quezon City Jail. Hence, he would like to

post bail in the reduced amount of Five Thousand Pesos (Php5,000.00) for
his provisional liberty;

3. The accused is in dire financial need and has no means to pay the
whole amount of bail, thus, he cannot post the recommend bond for his
provisional liberty, and will rely on his family and friends for financial
assistance. A copy of his Certificate of Indigency to prove that the accused
belongs to the indigent family and unemployed is hereto attached and marked as
ANNEX “1”;

4. Under Section 3 of A.M. No. 12-11-21, if the accused does not have
the financial ability to post the amount of bail that the court initially fixed, he
may move for its reduction, submitting for that purpose such documents or
affidavits as may warrant the reduction he seeks;

5. The Supreme Court Committee for the Decongestion of Provincial

City and Municipal Jails has recommended for the adoption of guidelines for

1
Guidelines For Decongesting Holding Jails By Enforcing The Rights Of Accused Persons To Bail And To
Speedy Trial.

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decongesting holding jails by enforcing the rights of accused persons to bail and
to speedy trial;

6. Considering that the accused is still presumed innocent until proven

guilty, as guaranteed by our Constitution and embodied in the Rules of
Court, we seek the indulgence of this Honorable Court to allow the accused to
post bond in a reduced amount in order for him to enjoy his temporary liberty
outside the congested Quezon City Jail.

PRAYER

WHEREFORE, premises considered and in the interest of substantial

justice, accused pray that he be allowed to post a cash bond in the amount of Five
Thousand Pesos (Php5,000.00).

Other relief, just and equitable under the premises, are likewise prayed
for.
Quezon City for the City of Manila, 02 October 2019.

____________

REQUEST FOR and NOTICE OF HEARING

OFFICE OF THE CITY PROSECUTOR

Quezon City

GREETINGS:

Please submit the foregoing motion for the consideration and approval of
the Honorable Court on ___________________, at _________ 8:30 a.m.
without further arguments.

__________________

Copy furnished:

OFFICE OF THE CITY PROSECUTOR

Quezon City