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REPUBLIC OF THE PHILIPPINES

6TH JUDICIAL REGION


REGIONAL TRIAL COURT
Branch 32
Iloilo City

PEOPLE OF THE PHILIPPINES,


Plaintiff,
-versus- Criminal Case No. 5432-001
For: Swindling (Estafa)
ALAN A. CHUA,
Accused.
X--------------------------------------------X

URGENT MOTION TO POST BAIL

NOW COMES the Accused, by his undersigned attorney, to this


Honorable Court and most respectfully avers:

1. That the Accused has been charged with violation of Article 315 of
the Revised Penal Code otherwise known as Swindling or Estafa;

2. That the bail for his provisional release has been fixed at Ten
Thousand Pesos (P10,000.00);

3. Rule 114, Section 4 of the Rules of Court provides:

Sec. 4. Bail, a matter of right; exception. — All persons


in custody shall be admitted to bail as a matter of right, with
sufficient sureties, or released on recognize as prescribed by
law or this Rule (a) before or after conviction by the
Metropolitan Trial Court, Municipal Trial Court, Municipal
Trial Court in Cities, or Municipal Circuit Trial Court, and (b)
before conviction by the Regional Trial Court of an offense not
punishable by death, reclusion perpetua, or life imprisonment.

4. That the accused has been arrested on February 19, 2023, and is
currently detained at Iloilo City Police Station, Gen. Luna St., Iloilo
City.

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PRAYER

WHEREFORE, it is respectfully prayed unto this Honorable Court


that the Accused ALAN A. CHUA be allowed to post bail for his temporary
liberty pending trial of the criminal charge against him.

Other just and equitable reliefs are likewise prayed for.

Respectfully submitted.
Iloilo City, Iloilo, Philippines February 20, 2023.

ATTY. ANDREA B. DELOVIAR


Counsel for Accused
Deloviar Law Office, Jaro, Iloilo City
Notarial Commission valid until 12/31/2023
Roll of Attorney’s No. 743440
PTR No. 14344-000 Iloilo City 12/31/2023
IBP No. 123-54321 Iloilo City 12/31/2023
MCLE Compliance No. IV-01220-2020

NOTICE OF HEARING

THE BRANCH CLERK OF COURT


Regional Trial Court, Branch 32
Iloilo City

OFFICE OF THE CITY PROSECUTOR


Iloilo City

Greetings!

Please take notice that the foregoing Motion for shall be submitted for
the immediate consideration and approval of the Honorable Court on
February 21, 2023 at 9:00 o’clock in the morning.

Thank you.

ATTY. ANDREA B. DELOVIAR

Copy furnished:
CITY PROSECUTOR’S OFFICE
CLERK OF COURT
REGIONAL TRIAL COURT, BRANCH 32

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REPUBLIC OF THE PHILIPPINES)
PROVINCE OF ILOILO ) SS.
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VERIFICATION

I, ALAN A. CHUA, of legal age, Filipino, and address at San Pedro,


Jaro, Iloilo City Iloilo, Philippines after having been sworn into in
accordance with law, do hereby depose and state that:

1. I am the Accused in the above-caption Urgent Motion to Post Bail;


2. I have read the same and the contents thereof are known to me to be
true and correct based on my own personal knowledge and authentic
records attached in the Motion itself and made part of the records of this
Case.

IN WITNESS WHEREOF, I hereunto affix my signature this


February 20, 2023 at Iloilo City, Philippines.

ALAN A. CHUA
Affiant
Driver’s License No. 5555-1309,
Iloilo City

SUBSCRIBED AND SWORN TO BEFORE ME, this February 20,


2023 at Iloilo City, Philippines.

ATTY. ANDREA B. DELOVIAR


Counsel for Accused
Deloviar Law Office, Jaro, Iloilo City
Notarial Commission valid until 12/31/2023
Roll of Attorney’s No. 743440
PTR No. 14344-000 Iloilo City 12/31/2023
IBP No. 123-54321 Iloilo City 12/31/2023
MCLE Compliance No. IV-01220-2020

Doc. No. 20;


Page No. 4;
Book No. 1;
Series of 2023
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