Republic of the Philippines

FIFTH JUDICIAL REGION

Province of Catanduanes
th
5 MUNICIPAL CIRCUIT TRIAL COURT
Bato-Baras
Bato, Catanduanes

EDDIE ARCILLA CUISON,

Complainant, CRIM. CASE No. _________

-versus-

BALWINDER SINGH.
Respondent.
x------------------------------------------------x

URGENT EX-PARTE
MOTION TO ADMIT TO BAIL

RESPONDENT, through undersigned counsel unto the Honorable Court most

respectfully manifests and moves:

1. That Respondent, has been detained by the Bato MPS for reckless

imprudence resulting in serious physical injury (NPS. No. V-11-INQ-

17D-00044) since Saturday April 22, 2017,

2. That the incident involves a minor victim and according to the Office

of the Provincial Prosecutor, the case falls within the jurisdiction of

the Honorable Municipal Trial Court. The police blotter certification

regarding said accident is hereto attached.

3. That for humanitarian reasons, Respondent is most humbly asking

that he be allowed to post a bail in an amount to be set by the

Honorable Court for his temporally liberty.

 PRAYER

WHEREFORE, premises considered and on grounds of equitable and humane

justice, Respondent through undersigned counsel, most respectfully prays that the

Honorable Court will GRANT the motion and set a bail for the Respondent to be

provisionally released.

Other relief just and equitable in the premises are also prayed for.

Virac, Catanduanes, for Virac, Catanduanes, April 26, 2017.

SUSAN U. UBALDE-ORDINARIO
Counsel for the Respondent
3 Rizal Ave., San Jose, Virac, Catanduanes
PTR No. 9521085/ 1-05-17 / Catanduanes
IBP No. 1045858 / 1-05-17 / Catanduanes
MCLE 5th Compliance #0019966/04-20-2016
Attorney’s Roll No. 44028

Copy furnished:

The BRANCH CLERK OF COURT

MTC, Bato, Catanduanes

GREETINGS:

Please submit the above pleading for the immediate consideration of the
Honorable Court without further arguments. Thank you.

SUSAN U. UBALDE-ORDINARIO