Republic of the Philippines

SUPREME COURT
10th Judicial Region
REGIONAL TRIAL COURT
Branch 22
ZZ, YY
-o0o-

PEOPLE OF THE PHILIPPINES,

Plaintiff,
CRIMINAL CASE No. ________

-versus- FOR: QUALIFIED THEFT

LEONEL ADOBO and RICKY

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

MOTION TO REDUCE BAIL BOND

COME NOW BOTH ACCUSED, through and by undersigned counsel, and unto this
Honorable Court, most respectfully moves for the reduction of the recommended bail
bond of the prosecution and thus alleges:

1. That the accused is charged with the above-cited offense and is now in jail having
voluntarily surrendered last December 9, 2010;

2. That the State recommended a bailbond for his temporary liberty in the amount
of Twenty Four Thousand (PhP24,000.00) pesos each or its equivalent in case of
surety or property bond;

3. That both of the accused have no visible means of livelihood to come up with bail
recommended by the Provincial Prosecutor. Annex “A and Series” is the
Certificate of Indigency issued by Municipal Social Welfare and Development
Office, ZZ, YY showing the indigency of both the accused;

4. That both the accused could not afford the said bail of Php24,000.00 each, and
thereby humbly asks of this Honorable Court that the said bail be reduced from
Twenty Four Thousand (Php24,000.00) Pesos each to only Ten
Thousand (Php10,000.00) Pesos each. The latter amount could be raised by
both the accused through the help of family members and well-meaning friends,
despite the fact that the same is still a considerable amount of money;

Page 1 of 3
 5. That they promise to be available anytime the Honorable Court needs their
personal presence and are willing and able to comply with the conditions of their
reduced bail bond in the amount of Php10,000.00 each.

6. That both the accused have the purest of intentions to face the indictment in
Court to prove their innocence;

7. That for these reasons, it is most respectfully prayed unto the Honorable Court
that the recommended bail bond in the amount of Twenty Four Thousand
(PhP24,000.00) Pesos each be reduced to Ten Thousand (PhP10,000.00) Pesos
each.

WHEREFORE, premises well considered, it is respectfully prayed unto this

Honorable Court that an Order be issued reducing the recommended bail bond in the
amount of Twenty Four Thousand (PhP24,000.00) Pesos each to Ten Thousand
(PhP10,000.00) Pesos for each accused.

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

January 5, 2010, ZZ, YY.

ATTY. TREVOR J. REYES

IBP No. 421199, Nov. 10, 2009
PTR No. 1234018, January 5, 2010
Attorney’s Roll No. 109999
MCLE Compliance No III-0001738

Copy furnished through Personal Delivery to:

Hon. Mildred Acutana

Provincial Prosecutor Public Prosecutor’s Office
ZZ, YY
Date: _________________

ATTY. Maria Angelica Ramirez

Clerk of Court
Regional Trial Court, Br. 22
ZZ, YY

Greetings:

Please submit the foregoing Motion to Reduce Bail Bond for the immediate
consideration of the Honorable Court sans further oral arguments.

Page 2 of 3
 TREVOR J. REYES

Hon. Mildred Acutana

Provincial Prosecutor
Public Prosecutor’s Office
ZZ, YY

Greetings:

Please take notice that the undersigned counsel will submit the foregoing Motion to the
Honorable Court for its Resolution sans further oral arguments.

TREVOR J. REYES

Page 3 of 3