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Republic of the Philippines

REGIONAL TRIAL COURT


7th Judicial Region
Branch _____, Cebu City

PEOPLE OF THE PHILIPPINES,


Plaintiff, CRIM. CASE NO.:

- versus -
FOR: viol. of R.A. 9287
_______________,
Accused.
x - - - - - - - - -- - - - - - - - - - - - - - /

URGENT MOTION TO LIFT WARRANTOF ARREST;


REINSTATEMENT OF BAIL BOND and TO LIFT THE ORDER
DECLARING THE CASE TO BR TRIED IN ABSENTIA

Accused ______________, through Counsel, to this Honorable


Court respectfully avers: That

1. On ___________, the Accused failed to appear for his


hearing, thus, this Honorable Court issued an order for the
cancellation and forfeiture of the bail bond of the accused
____________________, a warrant of arrest to be issued
against her and that the case shall be try in absentia;

2. Accused already ________ year old, and was suffering from


diarrhea on the above-mentioned schedule hearing. She
informed the court in the afternoon, and presented herself to
the court staffs and her counsel, but could not wait for this
Honorable Court since her Diarrhea was acting up again,
and has to go home early as she could not control the same;

3. Accused sincerely apologize failing to appear in the


saidhearingsdue to circumstances beyond her control, and
will do her best to conscientiously attend its proceedings.

4. Accused can still be served with notices, summons,


subpoena and other court process at her above-mention
address;

PRAYER
Wherefore, accused respectfully pray for the lifting of the
warrant of arrest order by the court against the accused dated
______________ for the reinstatement of his bail bond and to lift
order declared the case to be tried in absentia. Other relief which are
just and equitable under the premises are likewise prayed for.

Respectfully submitted, this ____________ at Cebu City,


Philippines.

ATTY. _______________
Counsel for Accused
Roll No. XXXXXX
MCLE Compliance No. XXXXXXX
IBP No. XXXXXX, Jan/xx/xxxx
xxxxx Chapter

NOTICE OF HEARING

The Branch Clerk of Court


RTC Branch ______, Cebu City

HON. ______________
City Prosecutor

Greetings!

Please take notice that on ____________ at __________ am or


as soon as counsels can be heard, the foregoing motion will be
submitted for the consideration and approval of the Honorable Court.

Thank you.

______________________

Copy furnished:

_____________________
Office of the City Prosecutor
_________________
____________ Sin City