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REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION


REGIONAL TRIAL COURT
MAKATI CITY
BRANCH 1

PEOPLE OF THE PHILIPPINES,


Plaintiff,

- versus - Crim. Case No.


For:

Mr. A
Accused.
x----------------------------------------------x

COMMENT – OPPOSITION TO URGENT


MOTION TO REDUCE BAIL

PEOPLE by understand private prosecutor and unto this Honorable


Court by way of Comment – Opposition to the Urgent Motion to Reduce Bail
filed by accused through counsel, most respectfully state the following:

1. Other than claiming that he has asthma with medical expenses,


accused through counsel has not adduced any proof in support of said
claim.
2. It bears stressing that the purpose for bail is to guarantee the
appearance of the accused at the trial or in instances whenever so
required by the Honorable Court. As such, bail amount should be
high enough to assure the presence of the accused when required.
3. Herein accused has more that sufficient financial resources to post
bail as recommended by the Office of the City Prosecutor and
approved by the Honorable Court. Section 9, Rue 114 of the Revised
Rules of Criminal Procedure recommends to the courts consideration
of the financial resources of the accused and the nature and
circumstance of the offense charged, among others, in setting the
amount of bail. The original amount of bail set is fully in accord with
these guidelines and personal circumstance of the accused.
4. Partaking of the nature of a litigated pleading, the motion to reduce
bail should have been set for hearing. Accused through counsel failed
to do so.
5. Finally, the motion filed should be considered an unauthorized
pleading as counsel failed to indicate his compliance with the
requirements of the Mandatory Continuing Legal Education and is
therefore considered delinquent and inactive member of the IBP
(Rules 12 and 13, Bar Matter 850).
WHEREFORE, above premises considered, it is respectfully prayed that
the Urgent Motion to Reduce Bail filed by the accused through counsel be
denied for lack of merit.

Other reliefs just and equitable under the premises are likewise prayed
for.

Makati City, 9 January 2019.

ATTY. R