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Republic of the Philippines

REGIONAL TRIAL COURT


2nd Judicial Region

PEOPLE OF THE PHILIPPINES,


Plaintiff, CRIM. CASE NO. 20/21-2019

-versus- FOR: VIOLATION OF SEC. 28 E1


RA 10591/ VIOL OF OMNIBUS
FELICIANO BIYANG LADYONG, ELECTION CODE
Accused.
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URGENT MOTION TO LIFT WARRANT OF ARREST
WITH PRAYER FOR THE REINSTATEMENT
OF THE BAILBOND
Accused and his bodsman Sergio W. Dinulong, by themselves,
unto this Honorable Court, respectfully state:

1. That an order for the issuance of a bench warrant of arrest


against accused had been issued in open court on September
16, 2019 in the afternoon for he and his bodsman failed to
comply with the Order of the Honorable Court dated April 25,
2019;

2. It is respectfully submitted that the failure of the accused to be


present on said date was due to sickness. Herein accused had
been suffering from hypertension/high blood pressure three (3)
days prior to and continued for another two (2) days after the
scheduled hearing of his case, which practically prevented him
from attending his case. He went for consultation/check-up at
Bulanao Community Clinic and Clinical Laboratory as
evidenced by the hereto attached Medical Certificate issued by
Dra. Cynthia C. Dawey;

3. That sickness is a tempest that besets any person at any given


time;

4. That accused had no least intention to shun away from his case
and did not mean to belittle the proceedings of the case but
mainly for the reason afore-stated; and

5. Thus, herein accused begs the kind indulgence of the Honorable


Court, that the Warrant of Arrest against him be lifted and/or
recalled.
PRAYER
WHEREFORE, premises considered, in the interest of
substantial justice, it is respectfully prayed that this Motion be
favorably considered and LIFT the Warrant of Arrest against accused
and REINSTATE the bail bond previously posted by the Accused for
his provisional liberty.

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

RESPECTFULLY SUBMITTED.

By:

REQUEST

The Branch Clerk of Court


Branch 25, Regional Trial Court
Tabuk City, Kalinga

G R E E T I N G S:

Please submit the foregoing MOTION immediately for the kind


approval and consideration of the Honorable Court immediately upon
receipt hereof.

Copy Furnished: (personal service)

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