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Republic of the Philippines

REGIONAL TRIAL COURT


7th Judicial Region
Branch 22, Cebu City
PEOPLE OF THE PHIIPPINES,
Plaintiff,
-versus- Crim. Case No. CBU-85405
For: Robbery
RANEL ROXAS,
Accused.
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URGENT MOTION FOR RELEASE
ON RECOGNIZANCE

COMES NOW, minor-delinquent Ranel Roxas, through counsel, unto


this Honorable Court, most respectfully states THAT:

1. The minor stands charged in an Information filed on February 10,


2009, for the crime of Robbery allegedly committed on January 29, 2009;

2. He was a minor at the time of the alleged commission of the crime


having been born on December 3, 1991. A copy of his Certificate of Birth is
hereto attached as Annex 1 to prove such minority;

3. The minor is presently detained at Talisay City Jail located at


Maghaway, Talisay City, and a detention center in said City for adult
prisoner. He has been there since the filing in court of the above-
mentioned Information;

4. Section 35 of the “Juvenile Justice and Welfare Act of 2006”


(Republic Act No. 9344), which took effect on May 5, 2006, provides in part:

“Sec. 35. Release on Recognizance.- Where a child is


detained, the court shall order:

(a) the release of the minor on recognizance to his


parents and other suitable persons;

xxx

The court shall not order the detention of a minor in


jail pending trial or hearing of his/her case.”
(Italics provided for emphasis.)

5. The continued detention of the minor at the Talisay City Jail would
highly prejudice his welfare and development because aside from the fact
that the mentioned facility is intended only for adult prisoners, said minor
would like to enroll this coming June 2009 school enrollment in Guadalupe
High School or Tabunok High School as second year high school student;

6. The father of the minor delinquent Ronnie Roxas is willing to


accept the custody of his son and guarantees his appearance whenever
required by this Honorable Court.
PRAYER
WHEREFORE, in view of the foregoing, it is most respectfully prayed
of this Honorable Court to order the immediate release of the minor, Ronnie
Roxas to the custody of his father.
Other relief just and equitable under the premises are likewise
prayed for.
Cebu City, Philippines. May 14, 2009.
PUBLIC ATTORNEY’S OFFICE
Department of Justice
(Counsel for the Accused)
The Chief Justice Fernan Memorial, Hall of Justice, Capitol Site Cebu City
By:

CLYDE LELITH S. LOBEDICA


Public Attorney I
Roll No. 54817
IBP No. 754066 [01-05-09] Cebu City
Admitted to the Bar on April 2008

STATEMENT OF RECOGNIZANCE

I hereby accept custody of my son Ranel Roxas, who is the accused in


the above-captioned case, and I guarantee his appearance whenever
required by this Honorable Court.

Ronnie Roxas
(Father)

Hon. Benjo Luther MacioN (Benz Maz)


Asst. City Prosecutor, Talisay City

Hon. Branch Clerk of Court


RTC Branch 22, Cebu City

Greetings!

Please take notice…. and kindly submit the foregoing motion for the
consideration of this Honorable Court and have the same set for hearing on
May 21, 2009 at 8:30 in the morning. Thank you so much.

Clyde Lelith S. Lobedica

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