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Motion To Release Cash Bond-Format One

Juan Dela Cruz filed an ex-parte motion requesting the release of his cash bond with the Metropolitan Trial Court in Caloocan City. He had pleaded guilty to violating P.D. 1602 and paid a fine, but his public attorney failed to request the return of his cash bond posted for provisional liberty. Dela Cruz provided official receipts for the cash bond as evidence and asked the court to order its release.

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Josef Glenn Ruga
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484 views2 pages

Motion To Release Cash Bond-Format One

Juan Dela Cruz filed an ex-parte motion requesting the release of his cash bond with the Metropolitan Trial Court in Caloocan City. He had pleaded guilty to violating P.D. 1602 and paid a fine, but his public attorney failed to request the return of his cash bond posted for provisional liberty. Dela Cruz provided official receipts for the cash bond as evidence and asked the court to order its release.

Uploaded by

Josef Glenn Ruga
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOC, PDF, TXT or read online on Scribd
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Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION


METROPOLITAN TRIAL COURT
Branch 123, Caloocan City

PEOPLE OF THE PHILIPPINES,

-versus- CRIM CASE NO. 270151234


For: Violation of P.D. No. 1602

JUAN DELA CRUZ,


x-----------------------------------------------------x

EX-PARTE MOTION TO ORDER


RELEASE OF CASH BOND

ACCUSED, Juan Dela Cruz, through and by himself, and unto this
Honorable Court, most respectfully states---THAT:

1. During the last hearing held on August 26, 2020, Juan Dela
Cruz and his co-accused, assisted by PAO Counsel Atty. Juana Penelope,
pleaded guilty to the charge of violation of P.D. 1602 after their
arraignment;

2. Thereafter, the Hon. Court found all the accused guilty beyond
reasonable doubt of the offense charged (P.D. 1602) and sentenced them to
pay a fine of P1,000.00 plus P10.00 cost each;

2. Due to inadvertence, the assisting PAO Counsel failed to move


for the release and/or return of the cash bond posted by the undersigned
accused for his provisional liberty pending trial;

3. Accordingly, accused thru and by himself, respectfully moves


that a directive for the release of the cash bond that was posted for his
provisional liberty be ordered by the Honorable Court;

*Photostat copies of the corresponding Official Receipts for the Cash


Bond posted by the said accused are hereto attached as Annexes “1” & “1-
A”, respectively;

PRAYER
WHEREFORE, premises considered, it is respectfully prayed of this
Honorable Court, that an Order be issued directing the release of the cash
bond posted by the afore-named accused in the above-entitled case.
Other reliefs as are just and equitable in the premises are likewise
prayed for.

Pasay City, for Caloocan City, September 25, 2020.

RESPECTFULLY SUBMITTED.

JUAN DELA CRUZ


Accused/Movant

NOTICE

The Branch Clerk of Court


Metropolitan Trial Court
Branch 123
Caloocan City

Greetings:

The foregoing motion not being litigious, please submit the same to
the Honorable Court for consideration and approval immediately upon
receipt hereof, sans further arguments and appearance from the accused and
assisting PAO Counsel, Atty. Juana Penelope.

JUAN DELA CRUZ

Copy furnished:

ACP Dencio Padilla, Sr. (Personal)


Public Prosecutor
Office of the City Prosecutor
Justice Hall Building, near Brgy. 123,
along Congressional Road, North
Caloocan City

PAO Atty. Juana Penelope (Personal)


Public Defender
Office of the Public Attorney’s Office
Justice Hall Building, near Brgy. 123,
along Congressional Road, North
Caloocan City

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