REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Branch ___, Paranaque City

PEOPLE OF THE PHILIPPINES

Complainant, Criminal Case No.
-versus- For: Violation of Art.

BENJAMIN CRUZ y GABRIEL

Accused.
x-------------------------------------------------x
MOTION TO REDUCE BAIL
ACCUSED BENJAMIN CRUZ y GABRIEL, through undersigned counsel and
unto this Honorable Court, most respectfully avers that:

1. The accused is charged with Robbery and the bail for his provisional release
has been set at P48,000.00;

2. The accused has very limited means because he is jobless at the moment and
he relies only on his family for financial support. He is, therefore,
constrained to request for a reduction of the amount of bail;

3. Because of his dire financial situation, the accused can only raise the amount
of P24,000;

4. The accused expressly reserves the right to question the legality of his
warrantless arrest if the circumstances so warrant.

WHEREFORE, in view of the foregoing, the accused most respectfully prays that
he be allowed to post bail for the said case at a reduced CASH BOND in the
amount of P24,000.00;

Other reliefs just and equitable in the premises are likewise sought.

Paranaque City, February ___, 2019.

ATTY. BONG GABRIEL

Counsel for the Accused
PTR No. 172222E/1.10.19/P’que City
IBP No. 064530/1.10.19/PPLM
Roll No. 12345
MCLE Compliance No. VI-00088976/5.24.2018

1
 NOTICE OF HEARING

THE CLERK OF COURT

RTC Br. ___, Legislative Building
Paranaque City Hall
San Antonio Valley 1
Paranaque City

NORBERTO ROBERTO
ACP, Office of the City Prosecutor
6th Floor, Legislative Building
Paranaque City Hall
San Antonio Valley 1, Paranaque City

Kindly set the foregoing motion for consideration and approval of the Honorable
Court on February ___, 2019 at 8:30 am.

BONG GABRIEL

COPIES FURNISHED:
(through personal service)

THE CLERK OF COURT

RTC Br. ___, Legislative Building
Paranaque City Hall
San Antonio Valley 1
Paranaque City

NOUBERT T. OLIVEROS
ACP, Office of the City Prosecutor
6th Floor, Legislative Building
Paranaque City Hall
San Antonio Valley 1, Paranaque City