REPUBLIC OF THE PHILIPPINES
NATIONAL CAPITAL JUDICIAL REGION
                           REGIONAL TRIAL COURT
                            Branch ___, Paranaque City
PEOPLE OF THE PHILIPPINES
                 Complainant,                         Criminal Case No.
        -versus-                                      For: Violation of Art.
BENJAMIN CRUZ y GABRIEL
                                  Accused.
x-------------------------------------------------x
                        MOTION TO REDUCE BAIL
ACCUSED BENJAMIN CRUZ y GABRIEL, through undersigned counsel and
unto this Honorable Court, most respectfully avers that:
   1. The accused is charged with Robbery and the bail for his provisional release
      has been set at P48,000.00;
   2. The accused has very limited means because he is jobless at the moment and
      he relies only on his family for financial support. He is, therefore,
      constrained to request for a reduction of the amount of bail;
   3. Because of his dire financial situation, the accused can only raise the amount
      of P24,000;
   4. The accused expressly reserves the right to question the legality of his
      warrantless arrest if the circumstances so warrant.
WHEREFORE, in view of the foregoing, the accused most respectfully prays that
he be allowed to post bail for the said case at a reduced CASH BOND in the
amount of P24,000.00;
Other reliefs just and equitable in the premises are likewise sought.
Paranaque City, February ___, 2019.
                            ATTY. BONG GABRIEL
                             Counsel for the Accused
                       PTR No. 172222E/1.10.19/P’que City
                          IBP No. 064530/1.10.19/PPLM
                                 Roll No. 12345
                    MCLE Compliance No. VI-00088976/5.24.2018
                                                                                   1
                             NOTICE OF HEARING
THE CLERK OF COURT
RTC Br. ___, Legislative Building
Paranaque City Hall
San Antonio Valley 1
Paranaque City
NORBERTO ROBERTO
ACP, Office of the City Prosecutor
6th Floor, Legislative Building
Paranaque City Hall
San Antonio Valley 1, Paranaque City
Kindly set the foregoing motion for consideration and approval of the Honorable
Court on February ___, 2019 at 8:30 am.
                                                            BONG GABRIEL
COPIES FURNISHED:
(through personal service)
THE CLERK OF COURT
RTC Br. ___, Legislative Building
Paranaque City Hall
San Antonio Valley 1
Paranaque City
NOUBERT T. OLIVEROS
ACP, Office of the City Prosecutor
6th Floor, Legislative Building
Paranaque City Hall
San Antonio Valley 1, Paranaque City